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remain unpaid as of July 22, 1998. The tax liability in the
instant case arose during 1997 but remained unpaid as of July 22,
1998. Accordingly, section 6015 applies to the instant case.
Washington v. Commissioner, 120 T.C. 137, 145 (2003).
Section 6015(b)(1) requires the Commissioner to grant relief
from joint liability if the taxpayer satisfies the following
requirements: (a) The requesting spouse filed a joint return;
(b) on the joint return there is an understatement of tax
attributable to the erroneous items of one individual filing the
joint return; (c) the requesting spouse establishes that, in
signing the joint return, he or she did not know and had no
reason to know that there was such understatement; (d)
considering all the facts and circumstances, it is inequitable to
hold the requesting spouse liable for the deficiency in tax
attributable to such understatement; and (e) the requesting
spouse files her request for relief no later than 2 years from
the date the Secretary began collection activities against the
requesting spouse. A requesting spouse must satisfy all of these
requirements to qualify for section 6015 relief. Alt v.
Commissioner, 119 T.C. 306, 313 (2002), affd. 101 Fed. Appx. 34
(6th Cir. 2004). Except as otherwise provided in section 6015,
the requesting spouse bears the burden of proving she satisfies
each requirement of section 6015(b)(1). See Rule 142(a); Alt v.
Commissioner, supra at 311.
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