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in the notice of deficiency attributable or allocable to Ms.
Weiler, (2) Mr. Weiler seeks relief from the penalties and
interest on the items in the notice of deficiency attributable or
allocable to himself, and (3) Ms. Weiler seeks relief pursuant to
section 6015(b) and (c) from all the items in the notice of
deficiency.
In general, spouses filing joint Federal income tax returns
are jointly and severally liable for all taxes due. Sec.
6013(d)(3). Under certain circumstances, however, section 6015
provides relief from this general rule.
At trial, respondent initially claimed that neither
petitioner was entitled to relief pursuant to section 6015(b) but
conceded that each petitioner was entitled to relief from
liability associated with certain items pursuant to section
6015(c). After initial statements by both petitioners, however,
respondent withdrew his concession that petitioners were entitled
to relief pursuant to section 6015(c). Respondent stated that he
wished to hear the testimony of petitioners before conceding that
petitioners were entitled to relief pursuant to section 6015(c).
A. Additional Schedule C Income of $14,065
Respondent increased petitioners’ Schedule C income by
$14,065.5 Respondent recharacterized the Schedule C income as
5 At trial respondent noted that the $1,250 in gross
receipts reported on Schedule C of the 1995 return is not an
(continued...)
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