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deficiency. Clark v. Commissioner, T.C. Memo. 2005-292.
Petitioner was not a party in Mr. Clark’s case. In this case,
petitioner has not challenged the determinations in the notice of
deficiency. Petitioner’s sole claim is that she is entitled,
under section 6015, to relief from joint liability for the 3
years in question.2 Mr. Clark was served with notice of this
case and his right to intervene. Mr. Clark did not file a notice
of intervention and did not appear or participate in the trial of
this case.
Petitioner and her spouse were married in 1975 and had three
children, all of whom were adults at the time of trial. On the
1998 return, one child was claimed as a dependent. None were
claimed as dependents on the subsequent returns.
Petitioner’s educational background included studies at a
vocational technical school, which was a part of Idaho State
University, where she took accounting and business math courses.
For approximately 25 years, petitioner’s employment was primarily
as a secretary, which, at times, involved accounting and
administrative record keeping. Petitioner’s spouse was an
accountant. At the time of trial, petitioner described her
2It follows that a decision in this case will be entered
against her for the determinations in the notice of deficiency,
and the Court will further decide on petitioner’s claim for
relief under sec. 6015. Except as otherwise provided in sec.
6015, petitioner bears the burden of proof. Rule 142(a); Alt v.
Commissioner, 119 T.C. 306, 311 (2002), affd. 101 Fed. Appx. 34
(6th Cir. 2004).
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