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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, it
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