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By notice of determination dated January 9, 2002, respondent
denied petitioner relief from joint and several liability under
section 6015(f) for taxable years 1989 through 1999. Although
section 6015(b) is not discussed in the notice of determination,
respondent’s Appeals Office also denied petitioner relief under
section 6015(b) because petitioner’s liabilities did not result
from an understatement of tax.
On February 21, 2002, petitioner filed her original petition
for relief from joint and several liability. On March 28, 2002,
petitioner filed her amended petition. Petitioner’s prayer for
relief does not specify the taxable years for which relief is
requested or the Internal Revenue Code provisions under which
relief is requested. It concludes: “I pray that I am found to
be not responsible for prior taxes my husband owes.”
Petitioner’s brief says she seeks relief under section 6015(f)
for her 1989 through 1997 tax years. In her petition, petitioner
says: “I always believed that my husband would pay his taxes.
In 1989, he paid over $30,000 in taxes, his entire tax plus all
penalties & late charges.” In her brief, petitioner says: “it
is reasonable for her to believe that at sometime her spouse
would pay the taxes. The same pattern had existed in the past
and the spouse had paid the taxes.” Petitioner says she believes
the tax liabilities for 1998 through 2001 have been paid.
On May 14, 2002, respondent filed an answer; on June 10,
2002, the Court filed respondent’s certification under interim
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Last modified: May 25, 2011