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petitioner hired an accountant to prepare such returns. Joint
returns for 1994, 1995, 1996, and 1997 were signed by petitioner
on March 14, 2000, and received by respondent on March 21, 2000,
and a joint return for 1998 was signed by petitioner on March 14,
2000, and received by respondent on March 20, 2000. The
accountant also prepared a joint return for 1999, which
petitioner timely filed. The foregoing joint tax returns,
collectively referred to as the returns, showed the following
amounts due for the respective years:
Tax Year Tax Liability
1994 $8,119
1995 7,862
1996 10,037
1997 14,447
1998 19,488
1999 3,740
1Respondent subsequently corrected a math error and
increased the balance due for 1997 to $4,873.
No portion of the amounts shown as due on the returns was paid at
the time of filing.
Respondent assessed petitioner’s Federal income taxes based
on the returns. The sum of tax, penalties, and interest assessed
against petitioner for the years in issue exceeds $115,000.
Respondent received from petitioner a Form 8857, Request for
Innocent Spouse Relief, and respondent denied that claim for
relief. Subsequently, respondent denied a request for
reconsideration of respondent’s prior decision and forwarded the
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