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for relief is that she was unemployed at the time the amended
return was filed and had no assets or other resources to pay the
tax liability. At the time of trial, however, petitioner was
employed.
Respondent denied petitioner's application for relief on the
ground that the tax liability in question was entirely
attributable to her income.
Generally, spouses filing a joint income tax return are each
fully responsible for the accuracy of their return and for
payment of the tax liability. Sec. 6013(d)(3); Butler v.
Commissioner, 114 T.C. 276, 282 (2000). Section 6015, however,
provides various means by which a spouse can be relieved of this
joint and several obligation. The Court's jurisdiction here
arises under section 6015(e), as petitioner's claim for relief is
based upon what is referred to generally as a "stand alone"
petition. Ewing v. Commissioner, 118 T.C. 494, 497 (2002).
Respondent considered petitioner's claim under section
6015(b), (c), and (f) and denied her application for relief.
With respect to relief under section 6015(b), in Washington
v. Commissioner, 120 T.C. 137, 146 (2003), this Court noted that
relief under that provision is based upon an "understatement" of
tax attributable to erroneous items of the other spouse. Here,
as in Washington v. Commissioner, supra, there is no
"understatement" of tax as defined in section 6662(d)(2)(A), nor
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