Philip Cullen - Page 18

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          return, that it did not include or otherwise report taxable                 
          income for 1999 earned by his wife from TGY.  The Court rejects             
          as not credible petitioner’s testimony that he could not contact            
          his wife, despite the fact she lived next to him in the travel              
          trailer and signed their joint tax return, to find out either the           
          amount of her TGY income or whether she had reported it to their            
          tax return preparer.                                                        
               Section 6013(d)(3) explicitly provides that “if a joint                
          return is made, the tax shall be computed on the aggregate income           
          and the liability with respect to the tax shall be joint and                
          several.”  The filing of a joint return may afford taxpayers                
          significant benefits in the form of lower taxes than would be the           
          case if they elected to file separately.  Therefore, unless                 
          relief is authorized by section 6015, each spouse should be held            
          liable for the tax due on a joint tax return.  In some cases,               
          this Court may afford section 6015(f) relief even though the                
          requesting spouse had knowledge of the tax deficiency or failure            
          to pay the tax when the return was signed and filed.  See, e.g.,            
          Foor v. Commissioner, T.C. Memo. 2004-54 (concluding that a                 
          multitude of favorable factors overcame the taxpayer’s knowledge            
          that the tax shown due would not be paid); Rev. Proc. 2000-15,              
          sec. 4.02, 2000-1 C.B. at 448 (specifying that no single factor             
          is determinative).  However, petitioner’s favorable facts in this           
          case are not sufficient to establish an abuse of respondent’s               






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