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tioner’s Form 8857:
ATTACHMENT
The understatement in tax for the periods in ques-
tion were due to investments and business activities of
my husband, [about] all of which I had no information
or knowledge.
During these periods I had employment and educa-
tional pursuits totally unrelated to my husband’s in-
vestment and business activities. All of the under-
statements in question were the results of an audit of
our tax return.
On September 12, 2002, in response to petitioner’s Form
8857, respondent issued to petitioner a notice of determination.
In that notice, respondent denied petitioner’s request for relief
under section 6015.
The liability for each of the taxable years 1989, 1991,
1992, and 1993 is from the assessment that respondent made for
each such year based upon the stipulated decision in the case for
the taxable years at issue. The liability for the taxable year
1990 is from the unpaid tax shown due in the original 1990 joint
return, plus interest thereon as provided by law, which respon-
dent assessed, plus an additional assessment of $3,978 to which
petitioner and Mr. Monsour agreed after the examination of the
taxable years at issue began and before respondent issued the
notice for the taxable years at issue.
OPINION
Burden of Proof
The parties agree that petitioner bears the burden of prov-
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