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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.
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