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Spruill’s business or personal bank accounts. Petitioner was not
in a position to insist upon examining Mr. Spruill’s business
receipts, deposits, and income, as he subjected petitioner to
physical and emotional abuse throughout their marriage.
Income Tax Deficiency
On November 9, 2000, following an examination of the 1998
return, respondent determined a deficiency in the Spruills’ 1998
income tax liability of $1,943 (the deficiency). The deficiency
resulted principally from the omission from the return of an item
of business income received by Mr. Spruill: $6,907 of gross
receipts from Thunder Alley Joint Venture (the Thunder Alley
receipts). Petitioner did not contest the deficiency, but, on
December 12, 2000, she did request relief from liability for the
deficiency as a so-called innocent spouse. On August 15, 2002,
respondent issued a notice of final determination (the notice)
denying petitioner’s request for innocent spouse relief.
Petition
On October 30, 2002, petitioner timely filed a petition
seeking our review of the notice.
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
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