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deficiency; and, by not reviewing the return, she did not satisfy
her duty of inquiry.
Petitioner argues in her petition that she is entitled to
relief from joint and several liability under section 6015
because Mr. Lathrop was responsible for the items of income that
gave rise to the 2000 tax liability, and she is unable to pay the
tax liability. Pursuant to Rule 325 and King v. Commissioner,
115 T.C. 118 (2000), respondent served Mr. Lathrop with notice of
this proceeding and his right to intervene. He did not, however,
file a notice of intervention and did not appear or participate
in the trial of this case.
A taxpayer may petition this Court for a review of the
Commissioner’s determination denying relief under section 6015.
Sec. 6015(e)(1)(A). Respondent issued a notice of deficiency for
the year at issue. The petition, however, was filed timely in
response to a final notice issued by respondent denying
petitioner’s request for section 6015 relief from her total
income tax liability for the taxable year 2000. Because a
deficiency was asserted for petitioner’s 2000 taxable year, the
Court has jurisdiction to review respondent’s denial of section
6015 relief for both the underpayment of tax and the deficiency
in tax, which form the basis of petitioner’s tax liability for
the year at issue. See Billings v. Commissioner, 127 T.C. 7
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