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Mr. Giles a notice of deficiency for taxable year 1995.
Respondent determined a deficiency for 1995 of $9,004 and an
accuracy-related penalty of $1,060.
Thereafter, pursuant to their divorce decree, petitioner and
Mr. Giles agreed that they will share their Federal and State tax
liabilities “in the same ratio as their respective incomes
contributed to their gross income.”
On July 1, 1999, petitioner submitted a Form 8857, Request
for Innocent Spouse Relief (And Separation of Liability and
Equitable Relief), to respondent.
On April 30, 2001, respondent denied petitioner’s Request
for Innocent Spouse Relief.
On April 11, 2003, respondent issued to petitioner a Notice
of Determination Concerning Your Request for Relief from Joint
and Several Liability under Section 6015 (notice of
determination). In the notice of determination, respondent
determined that petitioner was ineligible for relief under
section 6015(b), (c), and (f).
In her petition and amended petition, petitioner contends
that Mr. Giles filed their joint tax return for 1995, which
contained errors, and that Mr. Giles signed petitioner’s name on
the return.
Section 6013(d)(3) provides that spouses filing a joint
Federal income tax return are jointly and severally liable for
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