- 21 - OPINION I. Evidentiary Issue As a preliminary matter, we must decide whether a document petitioner submitted during the trial of this case should be admitted into evidence. At trial, petitioner sought to introduce a “fraud referral” memorandum for Walter J. Hoyt III (Exhibit 187-P). Respondent objected to the admission of Exhibit 187-P on the grounds of authentication, relevance, and hearsay. We reserved ruling on Exhibit 187-P’s admissibility. Petitioner failed to make any arguments regarding the admissibility of Exhibit 187-P in her opening brief. In her reply brief, petitioner stated: “Petitioner has addressed the relevance and purpose of Exhibit 187-P in her opening brief, in the context of proposed findings of fact.” For the reasons stated in Doyel v. Commissioner, T.C. Memo. 2004-35 (abandonment, hearsay, lack of authenticity, relevancy, and wastefulness), we do not admit Exhibit 187-P into evidence. II. Section 6015 Relief In general, spouses filing joint Federal income tax returns are jointly and severally liable for all taxes due. Sec. 6013(d)(3). Under certain circumstances, however, section 6015 provides relief from this general rule. Except as otherwise provided in section 6015, petitioner bears the burden of proof.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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