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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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