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Ms. Entezam and Mr. Zahedi were divorced in 1999. The
divorce judgment provides that Ms. Entezam and Mr. Zahedi are
each responsible for the payment of half of their Federal income
tax liabilities relating to 1990, 1991, and 1992.
By notice of deficiency dated June 1, 2000, respondent
determined that Ms. Entezam and Mr. Zahedi underreported gross
receipts of $64,915, $157,035, $148,717, and $154,940 on their
1989, 1990, 1991, and 1992 joint Federal income tax returns,
respectively.
On September 1, 2000, Ms. Entezam, while residing in
Escondido, California, filed a petition in which she requested
relief from joint and several liability. On January 11, 2001,
Mr. Zahedi, while residing in Lake Forest, California, filed his
notice of intervention. On July 12, 2001, an Internal Revenue
Service Appeals officer determined, pursuant to section 6015(f),
that Ms. Entezam did not qualify for relief.
OPINION
In limited situations, taxpayers filing joint Federal income
tax returns may be relieved from joint and several liability
pursuant to section 6015. Ms. Entezam, however, is not entitled
to such relief. Her actual knowledge of the tax understatement
precludes relief pursuant to section 6015(b) or (c). Sec.
6015(b)(1)(C) and (c)(3)(C); Jonson v. Commissioner, 118 T.C.
106, 115 (2002); Cheshire v. Commissioner, 115 T.C. 183, 193-194
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