Kathleen E. Gilliam - Page 4

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          other three Forms W-2, reflecting total wages of $4,464, were               
          issued to petitioner.                                                       
               The Form W-2 issued to Mr. Gilliam reflects withholding of             
          $1,077.  The three Forms W-2 issued to petitioner reflect zero              
          withholding.  The Federal income tax return for 2000 reflected a            
          refund of $1,077.  Petitioner and Mr. Gilliam received the refund           
          check and divided the proceeds.                                             
               After the separation and divorce, petitioner earned small              
          amounts of income from wages.  Petitioner has experienced                   
          economic hardship since her separation and divorce.                         
               Respondent determined in a notice of deficiency that                   
          petitioner and Mr. Gilliam omitted $4,464 in wage income from               
          their jointly filed 2000 Federal income tax return.  In her                 
          petition, petitioner does not dispute the omitted income but                
          rather asserts that she is entitled to relief under section 6015            
          because she did not prepare the return and did not know that her            
          wage income was omitted from the return.                                    
               Generally, married taxpayers may elect to file a joint                 
          Federal income tax return.  Sec. 6013(a).  After making the                 
          election, each spouse is jointly and severally liable for the               
          entire tax due.  Sec. 6013(d)(3).  A spouse may seek relief from            
          joint and several liability under section 6015.  A spouse may               
          qualify for relief from liability under section 6015(b), or if              

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