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Petitioner points the Court to Guth v. Commissioner, supra,
Price v. Commissioner, 887 F.2d 959 (9th Cir. 1989); Laird v.
Commissioner, T.C. Memo. 1994-564, and Estate of Killian v.
Commissioner, T.C. Memo. 1987-365, and argues that those cases
support her request for relief. We disagree.
First, although a requesting spouse’s lack of involvement in
family finances is one fact that may support a claim of relief
from joint and several liability under section 6015, that fact
standing alone may not always be enough for the spouse to receive
that relief. See Price v. Commissioner, supra at 443-444;
Stevens v. Commissioner, 872 F.2d 1499, 1507 (11th Cir. 1989),
affg. T.C. Memo. 1988-63; see also Hayman v. Commissioner, supra
at 1262 (requesting spouse was not relieved of her duty of
inquiry merely because she relied upon her husband to take care
of their tax returns); Jonson v. Commissioner, 118 T.C. 106,
119-120 (2002) (section 6015 relief unavailable where requesting
spouse did not establish that her husband concealed or attempted
to deceive her concerning couple’s financial affairs, and
requesting spouse had access to financial files), affd. 353 F.3d
1181 (10th Cir. 2003); Levin v. Commissioner, supra (taxpayer who
signed a blank joint return and then failed to inquire into her
tax liability as to that return turned a “blind eye” to that
liability and, thus, did not qualify for relief from joint and
several liability).
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