Zenobia Elisia Clary Ziegler - Page 7

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          submitted a joint status report requesting that respondent’s                
          determination of July 3, 2003, be made part of the record in this           
          case.  In that report, petitioner stated that she does not agree            
          with the conclusions reached in respondent’s July 3, 2003,                  
          determination, and the parties agreed that no further trial                 
          proceedings are needed to supplement the record in this case.               
               Generally, taxpayers filing a joint Federal income tax                 
          return are each responsible for the accuracy of their return and            
          are jointly and severally liable for the full tax liability.                
          Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C. 276, 282                  
          (2000).  However, in certain circumstances, a taxpayer may obtain           
          relief from joint and several liability under section 6015.3                
               The relief afforded by section 6015(f) is available only to            
          a taxpayer who filed a joint Federal income tax return for the              
          year at issue.  Raymond v. Commissioner, 119 T.C. 191 (2002);               
          see also Rev. Proc. 2000-15, 2000-1 C.B. 447.  In this case,                
          petitioner argues that she is entitled to relief under section              
          6015(f) from joint and several liability arising from the filing            
          of the 1998 joint return, but she also argues that she did not              
          file a joint return for 1998.  Although petitioner was aware that           

               3Sec. 6015 applies to tax liabilities arising after July 22,           
          1998, and to tax liabilities arising on or before July 22, 1998,            
          but remaining unpaid as of such date.  Internal Revenue Service             
          Restructuring and Reform Act of 1998, Pub. L. 105-206, sec.                 
          3201(g), 112 Stat. 740.                                                     

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