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         relief from joint and several liability under section 6015.  To              
         obtain relief from liability, a spouse must qualify under section            
         6015(b), or if eligible, may allocate liability under section                
         6015(c).  In addition, if relief is not available under section              
         6015(b) or (c), a spouse may seek equitable relief under section             
         6015(f).  Fernandez v. Commissioner, 114 T.C. 324, 329-331                   
         (2000); Butler v. Commissioner, 114 T.C. 276, 287-292 (2000).                
              Except as otherwise provided in section 6015, the taxpayer              
         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).               
         Relief Under Section 6015(b)                                                 
              Section 6015(b) provides relief from joint and several                  
         liability for tax (including interest, penalties, and other                  
         amounts) to the extent that such liability is attributable to an             
         understatement of tax.  To be eligible for relief, the requesting            
         spouse must satisfy the following five elements of section                   
                          (A) A joint return has been made for a                      
                   taxable year;                                                      
                          (B) on such return there is an                              
                   understatement of tax attributable to erroneous                    
                   items of 1 individual filing the joint return;                     
                          (C) the other individual filing the joint                   
                   return establishes that in signing the return he                   
                   or she did not know, and had no reason to know,                    
                   that there was such understatement;                                
                          (D) taking into account all the facts and                   
                   circumstances, it is inequitable to hold the other                 

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