Mary Jane Sylve, Petitioner, and Norman V. Sylve, Intervenor - Page 9

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          relief contemplated by subsections (b), (c), and (f), of section            
          6015.                                                                       
               In addition to other determinations made in the above-                 
          referenced notice of deficiency dated May 29, 2002, respondent              
          determined that petitioner was not entitled to relief under                 
          section 6015.                                                               
          Discussion                                                                  
               A. Duress                                                              
               Subject to a variety of conditions and limitations not                 
          relevant here, spouses “may make a single return jointly of                 
          income taxes”.  Sec. 6013(a).  If for any year they do, then “the           
          tax shall be computed on the aggregate income and the liability             
          with respect to the tax shall be joint and several.”  Sec.                  
          6013(d)(3).                                                                 
               Petitioner and intervenor signed and filed a joint 1998                
          Federal income tax return.  Petitioner now claims that she should           
          not be held liable for the subsequently determined deficiency               
          resulting from an examination of that return because she signed             
          that return under duress.                                                   
               If what purports to be a joint Federal income tax return is            
          signed under duress by a taxpayer, the document does not                    
          constitute a joint return, joint and several liability for the              
          tax reported on the return does not arise, and this Court has               
          jurisdiction to redetermine the taxpayer’s liability on the basis           






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