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The liabilities reported in the joint returns for the years
at issue (unpaid liabilities for the years at issue) are solely
attributable to Mr. Beatty. Petitioner did not review those
joint returns before she signed them. At the time petitioner
signed the joint returns for the years at issue, she believed
that Mr. Beatty would be incarcerated if she did not sign such
returns.
Around February 28, 2002, petitioner filed with respondent
Form 8857, Request for Innocent Spouse Relief (And Separation of
Liability and Equitable Relief), with respect to, inter alia,
taxable years 1988 through 1997 and 2000. Petitioner attached a
statement to that form, which stated in pertinent part:
Mrs. Beatty is not responsible, and should not be held
liable, for the underpayment of tax reflected on the
joint returns filed. First, she signed the returns
solely because she was instructed to do so by her
husband’s accountant. She was not advised nor was she
aware that she had the option of filing separately.
She was not told that by signing the returns, she was
jointly and severally liable for any tax reported
thereon. She would not have understood the information
reported as all items, with the sole exception of her
wages, were attributable to her husband and his busi-
ness, of which she had no knowledge. And, most impor-
tantly, she was told that failure to promptly file all
prior federal and state tax returns would result in her
husband going to jail.
On or about April 25, 2002, at the request of respondent,
petitioner submitted to respondent Form 886-A, Innocent Spouse
Questionnaire (petitioner’s Form 886-A). In petitioner’s Form
886-A, petitioner provided the responses indicated to the follow-
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