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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.
Discussion
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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