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several liability for each of those years.9 In each of those
forms, the only reason given by petitioner for seeking relief was
that the liabilities in question "arose out of payroll taxes for
my husband in his business."
By letter dated December 20, 2001, respondent's tax auditor
requested that petitioner complete a questionnaire and explain
why petitioner believed that she is entitled to relief under
section 6015. Around March 5, 2002, petitioner returned that
questionnaire, in which she stated that relief should be granted
because the "Taxes due on the returns were payroll taxes arising
out of my husbands [sic] law practice." In responding to the
questionnaire, petitioner failed to answer the question relating
to whether she was aware of the liability reported in Form 1040
that she and Mr. Butner filed for each of the taxable years 1994,
1995, 1998, and 1999 and whether she thought that such liability
would be paid at the time of each such filing. Petitioner
admitted in the questionnaire that there was no plan for paying
the liability reported in Form 1040 that she and Mr. Butner filed
9On Jan. 22, 2001, petitioner also filed Form 8857 with
respect to each of the taxable years 1996 and 1997, in which she
requested relief under sec. 6015 from joint and several liability
for each of those years. There were no unpaid liabilities
reflected in the respective income tax returns that petitioner
and Mr. Butner filed for the taxable years 1996 and 1997, and
respondent determined no deficiency in tax for either of those
years. Petitioner did not place the taxable years 1996 and 1997
at issue in the instant case. Our discussion hereinafter is
limited to the taxable years 1994, 1995, 1998, and 1999.
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