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those circuit courts and dismissed David’s case for a lack of
jurisdiction.
David appealed our decision to the Tenth Circuit (he was a
resident of Kansas when he filed his petition). Congress amended
section 6015 to give us jurisdiction over nondeficiency stand-
alone cases, and the Tenth Circuit remanded the case to us for
reconsideration. We then ordered the parties to report whether
the Billingses’ tax liability remained unpaid, and they recently
filed a stipulation agreeing that it did.
OPINION
As we summarized this part of tax law in our earlier
opinion, Billings I, 127 T.C. at 11-12, a married couple who file
their Federal tax return jointly are both responsible for the
return’s accuracy and are both jointly and severally liable for
the entire tax due. Sec. 6013(d)(3); Butler v. Commissioner, 114
T.C. 276, 282 (2000). Section 6015, however, directs the
Commissioner to relieve qualifying innocent spouses from that
liability under certain circumstances. Sec. 6015(a). An
innocent spouse may seek relief from liability under section
6015(b) if he can show that he was justifiably ignorant of
unreported income or inflated deductions. He may have his tax
liability allocated between himself and an estranged or former
spouse under section 6015(c). Or, like David, he may look to
section 6015(f) for relief. Subsection (f) relief is available
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