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OPINION
Generally, married taxpayers may elect to file a joint
Federal income tax return. Sec. 6013(a). Section 6013(d)(3)
provides that taxpayers filing a joint return are jointly and
severally liable for all taxes due. However, under certain
circumstances, section 6015 provides relief to taxpayers seeking
to be relieved from joint and several liability. Section 6015
offers three types of relief: (1) Full or partial relief under
section 6015(b); (2) proportionate relief under section 6015(c);
and (3) equitable relief under section 6015(f). Petitioner seeks
relief from joint and several liability under section 6015(b), or
in the alternative, section 6015(f). We have jurisdiction to
determine whether equitable relief is available to petitioner for
the deficiency in tax shown on her joint return. See Ewing v.
Commissioner, 118 T.C. 494, 502 (2002).
The taxpayer who files a petition under section 6015(e)
generally bears the burden of proof with certain exceptions not
applicable in this case. Rule 142(a); Alt v. Commissioner, 119
T.C. 306, 311 (2002), affd. 101 Fed. Appx. 34 (6th Cir. 2004);
Jonson v. Commissioner, 118 T.C. 106, 113 (2002), affd. 353 F.3d
1181 (10th Cir. 2003); Baumann v. Commissioner, T.C. Memo.
2005-31. However, the burden of proof issue does not influence
the outcome of this case because our decision is based on the
preponderance of the evidence. See Blodgett v. Commissioner, 394
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