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did not determine at that time what portion of the underpayment
was attributable to petitioner, but she did conclude that
petitioner was not entitled to relief under section 6015(f).
On or about July 19, 2004, petitioner appealed Ms. Wilce’s
denial of relief. On or about March 30, 2005, Appeals Officer
Leslie Hackmeister (Ms. Hackmeister) reviewed petitioner’s
appeal. In the case memorandum she prepared reflecting her
review, Ms. Hackmeister stated, among other things, that the
underpayment is attributable to Mr. Parker’s self-employment
income.
On March 30, 2005, respondent issued a Notice of
Determination denying petitioner’s request for relief under
section 6015(f). On June 24, 2005, a petition contesting
respondent’s determination was filed with this Court.
Discussion
In general, spouses who file a joint Federal income tax
return are jointly and severally liable for the full amount of
the tax liability shown or required to be shown on the return.
Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C. 276, 282
(2000). However, a spouse may seek relief from joint and several
liability under section 6015 if certain requirements are met.
In this case petitioner seeks equitable relief under section
6015(f). Section 6015(f) provides:
SEC. 6015(f). Equitable Relief.--Under procedures
prescribed by the Secretary, if--
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