Nora Aranda - Page 10

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          with respect to 1985 and 1986, and the relief granted to                    
          petitioner is consistent with a determination made under section            
          6653(b)(4).7                                                                
               We hold, therefore, that petitioner is not entitled to any             
          relief from joint and several liability for the 1985 and 1986               
          assessments under section 6015(b) in excess of that already                 
          granted by respondent.  We do not address whether petitioner                
          qualifies for relief from joint and several liability under                 
          section 6015(c) or (f) because petitioner has not requested                 
          relief under those provisions.                                              
               We have considered the remaining arguments of petitioner for           
          a contrary result and, to the extent not discussed above, find              
          those arguments to be irrelevant, moot, or without merit.                   
               To reflect the foregoing,                                              
                                                   Decision will be entered           
                                             for respondent.                          








               7Sec. 6653(b)(4) provides that a spouse who files a joint              
          return shall not be liable for the addition to tax for fraud                
          unless some part of the underpayment is due to the fraud of that            
          spouse.  In a deficiency suit, the Commissioner bears the burden            
          of proving by clear and convincing evidence that some part of an            
          underpayment is due to the fraud of that spouse.  See sec.                  
          7454(a); Rule 142(b).                                                       





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