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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.
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