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Secs. 6015(b)(3), 6662(d)(2)(A); Washington v. Commissioner,
supra at 146 n.5. In this case, there is no understatement of
tax because the amount of tax required to be shown on the return
is the amount shown on the return. Thus, petitioner is not
entitled to relief under section 6015(b).
C. Whether Petitioner Is Entitled to Relief From Joint
Liability Under Section 6015(c)
Petitioner contends that he is entitled to relief from joint
liability under section 6015(c). We disagree. Section 6015(c)
provides relief from a tax liability resulting from a deficiency
on a joint return for taxpayers who are divorced, legally
separated, or otherwise living apart. There is no deficiency in
this case because the amount of tax required to be shown on the
return is the amount of tax shown on the return. See sec.
6211(a). Thus, petitioner is not entitled to relief from joint
liability under section 6015(c). See Washington v. Commissioner,
supra at 147.
D. Whether Petitioner Is Entitled to Relief From Joint
Liability Under Section 6015(f)
1. Relief Under Section 6015(f)
Section 6015(e) gives this Court jurisdiction to determine
whether a taxpayer is entitled to relief from joint liability
under section 6015. As a result, a taxpayer is entitled to
relief from joint liability under section 6015(f) if the Court
determines that, taking into account all the facts and
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