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Petitioner filed a petition for judicial review of
respondent’s determination to deny her relief from joint and
several liability under section 6015 on her jointly filed income
tax returns for 1994 and 1995. The sole issue for decision is
whether it was an abuse of discretion for respondent to deny
petitioner’s request for relief under section 6015.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. When she filed her
petition, petitioner was a resident of Canoga Park, California.
Petitioner and her now-deceased husband, Willie C. Jones,
filed joint Federal income tax returns for taxable years 1994,
1995, and 1996. Income tax liabilities were self-assessed on the
joint returns, but the taxes were not paid in full.
Petitioner’s husband died on August 12, 1997. On February
3, 1998, following a notice and demand for payment, petitioner
paid respondent $8,398.56. This amount was reflected in
respondent’s records as payment in full of petitioner’s
outstanding tax liabilities for 1994, 1995, and 1996.
On July 11, 2003, petitioner filed a Form 8857, Request for
Innocent Spouse Relief, seeking relief from joint and several
liability on her jointly filed returns for 1994, 1995, and 1996.
Generally, petitioner stated that she is entitled to relief
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