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supra; King v. Commissioner, supra; Ockrant v. Commissioner,
supra; Worth v. Commissioner, supra. Respondent's determination
disallowing petitioners' deduction for unreimbursed employee
business expenses is sustained.
2. Relief From Joint and Several Liability Under Section 6015
Generally, married taxpayers may elect to file a joint
Federal income tax return. Sec. 6013(a). After making the
election, each spouse is jointly and severally liable for the
entire tax due. Sec. 6013(d)(3). A spouse may seek relief from
joint and several liability under section 6015. A spouse may
qualify for relief from liability under section 6015(b), or if
eligible, may allocate liability under section 6015(c). In
addition, if relief is not available under section 6015(b) or
(c), an individual may seek equitable relief under section
6015(f). Fernandez v. Commissioner, 114 T.C. 324, 329-331
(2000); Butler v. Commissioner, 114 T.C. 276, 287-292 (2000).
The Court's review is not limited to the Commissioner's
administrative record. Ewing v. Commissioner, 122 T.C. 32, 44
(2004).
Except as otherwise provided in section 6015, the taxpayer
bears the burden of proof. Rule 142(a); Alt v. Commissioner, 119
T.C. 306, 311 (2002), affd. 101 Fed. Appx. 34 (6th Cir. 2004).
Ms. Wang seeks relief from liability under section 6015 with
respect to respondent's adjustments to the 1999 return for the
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