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of settled issues, a power of attorney, and stipulations of
facts.
At the trial in Huynh v. Commissioner, supra, petitioner
testified and stated that she knew that Hong had credit card
insurance to cover a portion of his credit card debt if he should
become unemployed and that in 1996 and 1997 she knew Hong was
unemployed. Petitioner also signed a trial brief, a reply brief,
and a motion for leave to file a reply brief.
On August 30, 2001, the Tax Court filed its opinion in
Huynh, sustaining respondent’s tax deficiencies against
petitioner and Hong.
In March and April of 2002, petitioner requested section
6015 relief from joint liability for 1996 and 1997 with regard to
the above tax deficiencies that had been sustained by the Court.
Respondent denied petitioner’s claims for section 6015 relief,
and petitioner filed the instant action.
OPINION
Spouses filing joint Federal income tax returns generally
are jointly liable for all taxes due. Sec. 6013(d)(3). However,
under certain circumstances, a spouse may be relieved of
liability on a joint return. Sec. 6015.
Even after a final opinion has been filed by a court in
litigation involving joint filers’ Federal income tax liability,
the opinion may not be conclusive with respect to a requesting
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