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request relating to 2001 because he determined that petitioner
knew or had reason to know of the underpayment, the underpayment
was not solely attributable to Mr. Bracy, petitioner knew or had
reason to know that Mr. Bracy would not pay his half of the 2001
liability, petitioner had not been in compliance with Federal
income tax laws, and payment of the liability would not create
economic hardship.
On November 30, 2005, petitioner, while residing in
Carthage, Illinois, filed her petition with the Court.
OPINION
Married taxpayers may elect to file a joint Federal income
tax return. Sec. 6013(a). Each spouse filing the return is
jointly and severally liable for the accuracy of the return and
the entire tax due. Sec. 6013(d)(3). Pursuant to section
6015(a), however, a taxpayer may seek relief from joint
liability.
With respect to the 2000 understatement, petitioner contends
she is entitled to relief from liability pursuant to section
6015(b), (c), or (f). To qualify for relief pursuant to section
6015(b), the requesting spouse must establish that: A joint
return was filed; there was an understatement of tax attributable
to erroneous items of the nonrequesting spouse; at the time of
signing the return, the spouse seeking relief did not know and
had no reason to know of the understatement; the requesting
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