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the burden of proving that claim. See Alt v. Commissioner,
119 T.C. 306, 311 (2002), affd. 101 Fed. Appx. 34 (6th Cir.
2004); see also Rule 142(a)(1).
Section 6015(b) provides relief from joint and several
liability to the extent that the liability is attributable to an
understatement of tax. To be eligible for this relief, a
requesting spouse needs to satisfy the following five elements of
section 6015(b)(1):
(A) a joint return has been made for a taxable
year;
(B) on such return there is an understatement 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
circumstances, it is inequitable to hold the other
individual liable for the deficiency in tax for such
taxable year attributable to such understatement; and
(E) the other individual elects (in such form as
the Secretary may prescribe) the benefits of this
subsection * * *.
The requesting spouse’s failure to meet any one of these
requirements prevents him or her from qualifying for section
6015(b) relief. Alt v. Commissioner, supra at 313.
Respondent concedes that the elements of subparagraphs (A)
and (E) have been satisfied and focuses on the remaining
subparagraphs. Respondent argues that Ms. Ford meets none of
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