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In response to respondent’s March 12, 2004, determination
letters, petitioner on March 31, 2004, timely filed a Petition
for Lien or Levy Action Under Code Section 6320(c) or 6330(d)
with this Court for the 1996 taxable year. On May 21, 2004,
respondent filed an answer to petitioner’s petition and a
certification under Rule 325(b). See King v. Commissioner, 115
T.C. 118 (2000). The certification confirmed that respondent
notified Mr. Magee that petitioner filed a claim for relief from
joint and several liability and that he could intervene. Despite
the notice, Mr. Magee has not intervened in this case.
OPINION
I. Contentions of the Parties
Petitioner contends that she is not required to file a
Federal income tax return for 1996. Specifically, she asserts
that she did not generate a sufficient amount of income to
require her to file a return. In addition, with respect to the
1996 joint return, petitioner maintains that she is entitled to
relief from joint and several liability because her former spouse
forged her signature on the return. Ultimately, petitioner
claims that she never received a notice of deficiency for 1996,
that 1996 joint return was invalid, that liability on the 1996
joint return was incorrect, and that she was not given a proper
6(...continued)
income tax return for 1996.
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