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deficiencies for 1979 through 1982. On July 24, 2000, before
respondent replied to Lora’s request for relief, Lora filed an
amended petition, specifically requesting relief under section
6015(b) and (c) from joint and several liability. On July 9,
2001, respondent determined Lora was entitled to relief from
joint and several liability under section 6015(c) for each year
in issue. Isaac disputes respondent’s determination that Lora is
entitled to relief from joint and several liability.
OPINION
Taxpayers filing joint Federal income tax returns are
generally jointly and severally liable for all taxes due. Sec.
6013(d)(3). Relief from joint liability is available in limited
circumstances under section 6015. Sec. 6015(b), (c), (f). Lora
claims she is entitled to relief from joint and several liability
under section 6015(b) and (c). Lora makes no claim for equitable
relief under section 6015(f).
Generally, relief is available under section 6015(c) with
respect to taxpayers who are divorced, legally separated, or
living apart from the spouse with whom he or she filed a joint
income tax return for the year in issue. Such relief is
available only to taxpayers who establish that the items giving
rise to the deficiency are allocable to the former spouse.
Relief is not available where respondent establishes that a
taxpayer had actual knowledge of the items allocable to the
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