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the tax liability for 2001 at the time the return was filed.3
These circumstances prompted petitioner to enter into another
installment agreement with the IRS. Respondent issued a
preliminary determination letter on May 12, 2003, denying
petitioner’s request for relief under section 6015(f).
Respondent denied relief for the reason that the tax liabilities
were associated with income earned exclusively by petitioner.
Petitioner appealed this determination. On August 19, 2004,
respondent issued a Notice of Determination Concerning Your
Request for Relief Under the Equitable Relief Provision of
Section 6015(f) to petitioner denying him relief from joint and
several liability under section 6015(f) for taxable years 2000
and 2001.
Petitioner argues in his petition that he is entitled to
relief from joint and several liability under section 6015(f).
The petition sets forth a number of arguments; yet, they all
support one proposition: but for Ms. Peet’s actions, the
outstanding tax liabilities would be paid. Pursuant to Rule 325
and King v. Commissioner, 115 T.C. 118 (2000), respondent served
3Pursuant to the terms of the divorce decree, petitioner was
required to pay, inter alia, $21,500 to Ms. Peet for her share of
the communal household. Ms. Peet was required to pay, among
other things, $7,508.08, her portion of the 2000 tax liability,
and one-fourth of the tax liability for 2001. Rather than pay
her share of the tax liabilities for the years at issue, upon
receipt of the $21,500 from petitioner, Ms. Peet kidnaped the
couple’s minor son on or about April 3, 2002, and fled the United
States.
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