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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.
OPINION
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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