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On December 15, 2003, petitioner filed a petition with the
Court for review of respondent's determination denying her
request for relief under section 6015 with respect to each of the
taxable years 1994, 1995, 1998, and 1999.
OPINION
In general, each of the spouses who file jointly an income
tax return is responsible for the accuracy of, and is jointly and
severally liable for the entire liability shown due in, such
return. Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C. 276,
282 (2000). In certain circumstances, a spouse may obtain relief
from such joint and several liability if the requirements of
section 6015 are satisfied.
Section 6015 applies to any liability for tax arising after
July 22, 1998, and to tax liabilities arising on or before July
22, 1998, that remain unpaid as of such date. Internal Revenue
Service Restructuring and Reform Act of 1998, Pub. L. 105-206,
sec. 3201(g), 112 Stat. 740. In the present case, the respective
liabilities of petitioner and Mr. Butner arose with respect to
the taxable years 1994, 1995, 1998, and 1999. The respective
liabilities of petitioner and Mr. Butner for the taxable years
1994 and 1995 arose before July 22, 1998, but remained unpaid as
of that date. The respective liabilities of petitioner and Mr.
Butner for the taxable years 1998 and 1999 arose after July 22,
1998. Section 6015 is applicable to the respective liabilities
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