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For the sake of completeness, we shall address whether,
assuming arguendo that we had not held that section 6015(g)(2)
precludes petitioner from the relief that she claims under section
6015(b) and (f), petitioner would be entitled to such relief.
Section 6015(b)
Introduction
Petitioner claims that she is entitled to relief under
section 6015(b) for each of the taxable years 1989, 1991, 1992,
and 1993.33 Section 6015(b) provides:
SEC. 6015. RELIEF FROM JOINT AND SEVERAL LIABILITY ON
JOINT RETURN.
* * * * * * *
(b) Procedures For Relief From Liability Applicable
to All Joint Filers.--
(1) In general.–-Under procedures prescribed
by the Secretary, if--
(A) a joint return has been made for a
taxable year;
(B) on such return there is an under-
statement of tax attributable to erroneous
items of 1 individual filing the joint return;
(C) the other individual filing the joint
return establishes that in signing the return
he or she did not know, and had no reason to
know, that there was such understatement;
(D) taking into account all the facts and
33In the alternative, petitioner claims relief under sec.
6015(f) for each of the taxable years 1989, 1991, 1992, and 1993.
She also claims relief under that section for the taxable year
1990.
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