- 17 - Information, for 2002 from Fidelity Investments issued to petitioner with a fair market value of $4,183.39 as of December 31, 2002; and their 2001 joint tax return which listed adjusted gross income of $92,840. OPINION I. Evidentiary Issue As a preliminary matter, we must decide whether a document petitioner submitted during the trial of this case should be admitted into evidence. At trial, petitioner sought to introduce a “fraud referral” memorandum for Walter J. Hoyt III (Exhibit 86- P). Respondent objected to the admission of Exhibit 86-P on the grounds of authentication, relevance, and hearsay. We reserved ruling on Exhibit 86-P’s admissibility. Petitioner failed to make any arguments regarding the admissibility of Exhibit 86-P in her opening brief. In her reply brief, petitioner stated: “Petitioner has addressed the relevance and purpose of Exhibit 86-P in her opening brief, in the context of proposed findings of fact.” For the reasons stated in Doyel v. Commissioner, T.C. Memo. 2004-35 (abandonment, hearsay, lack of authenticity, relevancy, and wastefulness), we do not admit Exhibit 86-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.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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