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(2003) (holding that neither section 6015(b) nor (c) provides
relief from joint and several liability for the underpayment of a
tax liability that was properly reported on a joint return);
Block v. Commissioner, 120 T.C. 62, 65-66 (2003) (explaining that
a prerequisite for relief under both section 6015(b) and (c) is
the existence of a deficiency for which relief from joint and
several liability is sought); Ewing v. Commissioner, 118 T.C.
494, 497, 498 n.4 (2002); cf. sec. 6015(e)(1).
In the instant case, there was an understatement of tax on
the original joint return that resulted from the improper
treatment of the gain that petitioner realized on the sale of the
New York apartment. This understatement was partially corrected
by the first amended joint return, and it was completely
corrected when petitioner filed the second amended joint return
in November 1994. For purposes of computing the amount of a
deficiency for 1989, the total tax reported on the second amended
joint return is treated as the amount of tax shown by petitioner
on the original joint return. Sec. 6211(a); sec. 301.6211-1(a),
Proced. & Admin. Regs.; e.g., Pesch v. Commissioner, 78 T.C. 100,
111 (1982); cf. Laing v. United States, 423 U.S. 161, 173 (1976)
(a deficiency for a given year, reduced to its simplest terms, is
the correct amount of tax less the amount shown as tax on the tax
return). Consequently, there is no deficiency for 1989 for which
petitioner can seek relief. Accordingly, petitioner is not
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