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Petitioner did not significantly benefit from Alimam’s
failure to pay the tax balances shown to be due on their joint
Federal income tax returns.
For 1996 and subsequent years, petitioner has continued to
have income taxes withheld from her salary, has timely filed her
separate individual Federal income tax returns, and has paid in
full her Federal income tax liabilities.
Petitioner continues to support her three children
financially, two of whom are adults and not currently attending
school. On account of the bankruptcies, unpaid tax liabilities,
resulting poor credit, and other financial problems arising from
her marriage to Alimam, petitioner currently resides in a home
and drives a car owned by friends. Since her divorce from
Alimam, petitioner has not taken vacations, either with the
children or separately.
OPINION
Generally, taxpayers filing joint Federal income tax returns
are jointly and severally liable for all taxes due thereon. Sec.
6013(d)(3).
Taxpayers, however, may be relieved of joint and several
liability under limited circumstances described in section
6015(b), (c), and (f). Petitioner alleges that, on the
particular facts and circumstances of this case, respondent
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