Tracie Young - Page 6

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          Dissolution Agreement” which provides for a settlement of                   
          property rights of the parties.  Petitioner has not provided                
          respondent, respondent’s counsel, or this Court with a copy of              
          the aforesaid agreement.                                                    
               On or about April 1, 2002, respondent applied petitioner’s             
          2001 Federal income tax refund of $2,434 toward petitioner and              
          Mr. Glaze’s 1995 income tax liability.                                      
               On June 3, 2002, petitioner filed a Form 8857, Request for             
          Innocent Spouse Relief, with respondent, requesting innocent                
          spouse relief with respect to the 1995 taxable year.  On February           
          25, 2003, respondent issued petitioner a letter advising her of             
          the preliminary determination denying relief from liability on              
          the 1995 joint return.  On March 29, 2004, respondent sent                  
          petitioner a letter advising her of the final determination                 
          denying her relief from liability for the deficiency, addition to           
          tax, and penalty for the 1995 taxable year.  On April 12, 2004,             
          petitioner filed a petition with this Court for review of                   
          respondent’s determination denying her request for relief from              
          joint and several liability with respect to the 1995 tax year.              
               In general, taxpayers filing a joint Federal income tax                
          return are each responsible for the accuracy of their return and            
          are jointly and severally liable for the entire tax liability due           
          for that year.  Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C.           

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