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Petitioner and intervenor were divorced in 2001.
On October 1, 2001, petitioner submitted to respondent a
Form 8857, Request for Innocent Spouse Relief, requesting section
6015 relief. Petitioner lived apart from intervenor during the
12-month period preceding her request.
On November 5, 2001, petitioner submitted to respondent a
completed Innocent Spouse Questionnaire and related attachments.
On November 14, 2001, respondent received from intervenor a
Form 12507, Innocent Spouse Statement, and a Form 12508, Innocent
Spouse Information Request.
On March 11, 2002, respondent sent a preliminary letter to
petitioner notifying her that she was not entitled to relief
under section 6015.
In April 2002, petitioner submitted to respondent a Form
12509, Statement of Disagreement. Petitioner also submitted a
Form 433-A, Collection Information Statement for Wage Earners and
Self-Employed Individuals.
On October 11, 2002, respondent issued a notice of
determination advising petitioner that she was not entitled to
relief under section 6015.
Discussion
As a general rule, spouses filing a joint Federal income tax
return are jointly and severally liable for all taxes shown on
the return or found to be owing. Sec. 6013(d)(3); Cheshire v.
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