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respondent’s determination that the entire amount of the
deficiency in each year is attributable to a valuation
overstatement under section 6659, we likewise sustain
respondent’s determination that the section 6621(c) increased
rate of interest is applicable with respect thereto.
V. Relief Under Section 6015
In general, spouses filing joint Federal income tax returns
are jointly and severally liable for all taxes due with respect
to such returns. Sec. 6013(d)(3). Under certain circumstances,
however, section 6015 provides relief from joint and several
liability. There are three separate avenues of relief under
section 6015--section 6015(b), section 6015(c), and section
6015(f). Petitioner alternatively argues that she is entitled to
relief under each of these provisions.
A. Section 6015(b)
Section 6015(b) provides relief from liability for taxes,
including interest, penalties, and other amounts, that is
attributable to certain understatements appearing on joint
returns. To qualify for relief under section 6015(b)(1), a
taxpayer must establish:
(A) a joint return has been made for a taxable year;
(B) on such return there is an understatement of tax
attributable to erroneous items of 1 individual filing the
joint return;
(C) the other individual filing the joint return
establishes that in signing the return he or she did not
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