- 10 - the liabilities are attributable to Robledo. Her returns for the 3 years subsequent to 1990 were delinquent until 1995. We cannot conclude on this record that denial of relief was an abuse of discretion. 1991 The filing of a joint return is required for a taxpayer to be granted relief under section 6015. Raymond v. Commissioner, 119 T.C. 191 (2002). Because she filed a separate return for 1991 and the subsequent attempted election of joint return status was untimely under section 6013(b)(2), petitioner is not entitled to relief for 1991. 1992, 1993, and 1994 As detailed in our Findings of Fact, respondent has made concessions for 1992, 1993, and 1994. Respondent’s Appeals Office and petitioner’s representative determined an allocation of the liabilities for those years under section 6015(c). Petitioner has not contested the deficiencies or the allocations and has not shown that she is eligible for additional relief beyond that already granted to her. To be eligible for relief under section 6015(b), petitioner must show, among other things, that she did not know or have reason to know of the understatement of tax on the subject returns; that the understatements were attributable to Robledo; and that, taking into account all the facts and circumstances, itPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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