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properly to raise the issue of judicial or equitable estoppel, we
decline to allow them to raise it now.8
V. Section 6015(b) Relief
Ms. Ford requests section 6015(b) relief from joint and
several liability. Spouses filing a joint Federal income tax
return are generally jointly and severally liable for the tax
shown on the return or found to be owing. Sec. 6013(d)(3);
Butler v. Commissioner, 114 T.C. 276, 282 (2000). In certain
cases, however, an individual filing a joint return may avoid
joint and several liability for tax (including interest,
penalties, and other amounts) by qualifying for relief under
section 6015. The three types of relief prescribed in that
section are: (1) Full or apportioned relief under section
6015(b) (full or apportioned relief), (2) proportionate relief
under section 6015(c) (proportionate relief), and (3) equitable
relief under section 6015(f) (equitable relief). Ms. Ford claims
entitlement only to relief under section 6015(b). Ms. Ford bears
8 Petitioners would still not prevail even if these issues
were properly before us. Contrary to petitioners’ assertions on
this issue, the fact that Marc Ford may have paid tax on the
referenced $2.8 million does not mean that respondent is estopped
from determining the $2.8 million is rightfully taxed to
petitioners. Nor would a finding that petitioners were
“prevented” by respondent’s actions from filing an amended return
for 1986, on which they would have reported the disputed income,
serve to estop respondent from now asserting fraud. A taxpayer
who files a fraudulent return does not purge the fraud by a
subsequent voluntary disclosure. Badaracco v. Commissioner, 464
U.S. 386, 394 (1984).
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