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petitioner’s and intervenor’s joint income tax returns for 1990
through 1995.
Petitioner’s Request for Relief From Joint and Several Liability
On January 22, 1999, the IRS received petitioner’s Form
8857, Request for Innocent Spouse Relief, on which she requested
relief from joint and several liability under section 6015 with
respect to 1990 through 1995. On March 8, 2001, the IRS sent to
petitioner a Notice of Determination Concerning Your Request for
Relief from Joint and Several Liability under Section 6015
(notice of determination) with respect to those years. The
notice of determination set forth the following reasons for the
denial of petitioner’s request for relief from joint and several
liability:
We’ve determined, for the above tax years, that:
* * * * * * *
• You are not eligible for relief under Section
6015(f). Section 6015(f) allows us to provide
equitable relief when you don’t qualify for relief
under either Section 6015(b) or 6015(c) and when
holding you responsible for the tax liability
would be unfair or inequitable, given your
particular circumstances.
In this case, the unpaid liability is attributable to
interest and penalties on the taxes shown on the
returns you filed. Since there are no additional
deficiencies assessed subsequent to these taxes, relief
under sec. 6015(b) or sec. 6015(c) is not applicable.
For sec. 6015(f), relief is not warranted since you
have not established that payment of the amount due
would cause an economic hardship or that it would be
inequitable to hold you liable for these amounts.
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