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The Prices filed joint 1994 and 1995 Federal income tax
returns with the Commissioner on May 6, 1999. Those returns,
which were signed by both of the Prices, reported that the Prices
owed tax. As of January 8, 2003, the Commissioner’s records
reflect that the Prices’ liabilities as to those returns are
$1,892 and $1,159, respectively, exclusive of interest.
On May 15, 2000, respondent received from petitioner a
request for equitable relief under section 6015(f) as to 1994 and
1995. On or about November 21, 2001, Appeals Officer Bonnie Boak
(Boak) met with petitioner regarding his claim for equitable
relief under section 6015(f). Afterwards, following her research
and analysis of that claim, Boak issued to petitioner a notice of
determination denying it.
OPINION
Section 6015(f) generally affords a spouse equitable relief
from liability for tax owed as to a joint return where the facts
and circumstances of the case establish that it would be
inequitable to hold that spouse liable for that tax. Petitioner
argues that the Commissioner should have afforded him such
equitable relief for 1994 and 1995. According to petitioner, he
filed his 1994 and 1995 joint returns under duress in that the
judgment of divorce ordered that the Prices file joint income tax
returns for 1994 and 1995 and he was afraid of the consequences
of not filing joint returns for those years. Petitioner makes no
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Last modified: May 25, 2011