Cynthia Emery Weight - Page 6

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                  Petitioner’s section 6015(f) administrative claim for relief                          
            was made, presumably in writing, on August 8, 1999.  We cannot                              
            tell what statements, allegations, specific claims, etc. were                               
            made in her administrative claim because the document, if it                                
            exists, has not been made part of the record.  Nevertheless, it                             
            is clear from the petition, amended petition, second amended                                
            petition, and statements made at trial by petitioner’s counsel                              
            that petitioner’s claim for relief in this proceeding does not                              
            include the refund of any payments previously made with respect                             
            to her 1996 Federal income tax liability.                                                   
                  As noted, petitioner’s administrative claim for section                               
            6015(f) relief was denied by notice of final determination dated                            
            March 8, 2001.  In that notice, respondent:  (1) Acknowledges                               
            receipt of petitioner’s August 8, 1999, “request for innocent                               
            spouse relief under section 6015(f)”; (2) advises petitioner that                           
            respondent “cannot allow” petitioner’s claim and that, therefore,                           
            “both persons who signed the joint return remain responsible for                            
            paying the tax”; and (3) advises petitioner of her right to                                 
            petition this Court to request a review of respondent’s denial of                           
            her claim.                                                                                  
                  In general, if a taxpayer elects to file a joint Federal                              
            income tax return with his or her spouse, then the taxpayer and                             
            the taxpayer’s spouse are jointly and severally liable for the                              

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