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innocent spouse questionnaire. Presumably, that account was
closed before 1996. The residuary estate went to Louis’s four
grandchildren.
Petitioner’s Financial Circumstances After Louis’s Death
Petitioner’s attorney unsuccessfully attempted to trace the
proceeds of the IRA distribution.
The house, inherited by petitioner from Louis, was valued at
$247,000 at the time of Louis’s death and was mortgage free.
Since Louis’s death, petitioner has paid her customary living
expenses and generally maintained the same standard of living
that she maintained prior to his death.
OPINION
I. Introduction
As a general rule, spouses filing joint Federal income tax
returns are jointly and severally liable for all taxes shown on
the return or found to be owing. Sec. 6013(d)(3). In certain
situations, however, a joint return filer can avoid such joint
and several liability by qualifying for relief therefrom under
section 6015. There are three types of relief available under
section 6015: (1) full or apportioned relief under section
6015(b); (2) proportionate tax relief for divorced or separated
taxpayers under section 6015(c); and (3) equitable relief under
section 6015(f) when relief is unavailable under either section
6015(b) or (c).
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