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that she satisfied each requirement of section 6015(b)(1) in
order to obtain any additional relief from joint and several
liability for the 1985 and 1986 assessments. This petitioner
failed to do. For example, petitioner introduced no evidence
beyond the stipulated facts to prove that she had no knowledge or
reason to know that her 1985 and 1986 returns had understated the
tax liability of herself and Mr. Aranda or that it would be
inequitable to hold her liable for the 1985 and 1986 assessments.
Petitioner made a strategic decision not to offer additional
evidence and to rely instead on an argument based on an
interpretation drawn from a less than carefully drafted notice of
determination.6 In so doing, petitioner failed to carry her
burden of proof with respect to the requirements of section
6015(b)(1).
We also reject petitioner’s argument regarding the
interpretation of the notice of determination. Although the
notice of determination does not clearly state that the relief
provided by respondent was relief from the additions to tax for
fraud and related interest, nor does it mention section 6653(b),
the amounts listed in the notice of determination correspond
exactly to the amounts of the additions to tax for fraud assessed
6That decision may reflect a concern about what any
additional evidence might show. Respondent contends that
petitioner profited from the omitted income and may have had
reason to know that at least some of Mr. Aranda’s income was not
shown on the 1985 and 1986 returns.
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