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accountant, and respondent does not assert any tax deficiencies
in the taxes reported thereon.
Petitioner understood and assumed that Alimam, when he
mailed the above tax returns to respondent for 1993, 1994, and
1995, was including a payment for the full tax balances shown to
be due.
As indicated above, however, Alimam did not include any
payments in his mailing to respondent of the 1993, 1994, and 1995
joint Federal income tax returns.
Twice, petitioner’s wages or bank account were levied in
partial collection of the above unpaid joint Federal income
taxes.
Only in 1996, after separating from Alimam and after
speaking to Alimam’s accountant and lawyer for the first time,
did petitioner learn that Alimam had filed the above Federal
income tax returns without including payments of the tax balances
shown to be due thereon.
On February 8, 2000, petitioner made a timely election under
section 6015(f) for equitable relief from joint and several
liability relating to the above 1993, 1994, and 1995 unpaid taxes
attributable to Alimam’s income. On April 22, 2003, respondent
issued a notice of determination denying petitioner’s request for
equitable relief.
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