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Even were we to conclude that petitioner did not abandon
this issue, petitioner makes no argument regarding the
authenticity of Exhibit 120-P or why Exhibit 120-P is not
excludable as hearsay. Fed. R. Evid. 802-804, 807, 901.
Furthermore, petitioner’s belated, conclusory assertion in her
reply brief that Exhibit 120-P is relevant is insufficient. We
find Exhibit 120-P to be hearsay, lacking authenticity, not
relevant to the issue of petitioner’s being entitled to section
6015 relief. Furthermore, even if we did not so find, it would
be within our discretion to exclude Exhibit 120-P as wasteful.
Fed. R. Evid. 403.
Accordingly, we do not admit Exhibit 120-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.
Rule 142(a); Jonson v. Commissioner, 118 T.C. 106, 113 (2002),
affd. 353 F.3d 1181 (10th Cir. 2003).
In arguing that petitioner is entitled to relief pursuant to
section 6015, petitioner also relies on the regulations related
to section 6015. Sections 1.6015-0 through 1.6015-9, Income Tax
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