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Revenue Code in effect when the petition was filed. Pursuant to
section 7463(b), the decision to be entered is not reviewable by
any other court, and this opinion shall not be treated as
precedent for any other case.
Petitioner seeks equitable relief from joint and several
liability under section 6015(f) for unpaid Federal income taxes
arising from joint returns filed with Roberto E. Barrera (Mr.
Barrera) for taxable years 1998, 1999, and 2000.3
Background
Petitioner resided in Miami-Dade County, Florida, at the
time she filed her petition.
Petitioner and Mr. Barrera were married in June 1995.
Petitioner was not abused by Mr. Barrera at any time during their
marriage.
For the taxable years 1995 through 2002, petitioner and Mr.
Barrera filed joint Forms 1040, U.S. Individual Income Tax
Return. Petitioner did not prepare the joint returns; they were
2(...continued)
years in issue, and Rule references are to the Tax Court Rules of
Practice and Procedure.
3 Pursuant to Rule 325 and sec. 6015(e)(4), petitioner’s
former husband, Roberto E. Barrera (Mr. Barrera), was served with
notice of the filing of the petition in this case and his right
to intervene. Respondent represented at trial that Mr. Barrera
notified respondent, in a letter dated Mar. 16, 2004, and
received by respondent on Apr. 30, 2004, that he does not intend
to intervene in this matter. Petitioner did not dispute
respondent’s representation.
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