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her husband forged her signature on their joint return.12 The
Court addresses below petitioner’s contention that her signature
was forged on the joint return, but the Court notes that this
contention does not invalidate the joint return, and it also does
not place the validity of the underlying liability at issue.
Petitioner did not pursue her opportunities to discuss
collection alternatives with the Appeals officer such as a
possible installment agreement, offer-in-compromise, the posting
of a bond, or the substitution of other assets, and she did not
submit any financial information for the Appeals officer to
consider. See sec. 6330(c)(2)(A)(iii). The Appeals officer
verified that the legal and procedural requirements for
collection had been satisfied in her Collection Due Process
Explanation of Items.
IV. Filing of a Joint Return
Section 6013 allows a husband and a wife to file a joint
return. Generally, joint and several liability applies to all
joint returns. Sec. 6013(d)(3). Therefore, petitioner would
typically be jointly and severally liable for the payment of any
taxes due on the aggregate income. See id. Where a taxpayer has
consented to the filing of a joint return, such joint return may
be considered valid even if only one taxpayer signs the return.
Estate of Campbell v. Commissioner, 56 T.C. 1, 12-13 (1971);
12 See infra sec. IV for a discussion on the validity of a
joint return where only one spouse signed the return.
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