- 9 - trial, we do not need to consider whether testimony in addition to the administrative record may be considered. The stipulation includes documents that were not included in the administrative record in this case, and respondent has maintained a relevance objection to those documents. Because we agree with respondent’s relevance objection, we need not address respondent’s contention that we are limited to the administrative record. Married taxpayers who elect to file a joint Federal income tax return are jointly and severally liable for the entire tax due for the year of the return. Sec. 6013(d)(3). A spouse (a requesting spouse) may seek relief from joint and several liability by following the procedures established in section 6015. If the disputed liability involves nonpayment of taxes shown on a joint return, the only relief available is under section 6015(f). See Washington v. Commissioner, 120 T.C. 137, 146-147 (2003). Thus, the relief pursued by and granted to Ms. Holloway was relief under section 6015(f). Under the circumstances of this case, petitioner is fully responsible for the unpaid amounts, whether or not Ms. Holloway is also responsible. Petitioner has provided neither reason nor authority supporting his assertion that relief given to Ms. Holloway should preclude the proposed levy against his assets or that his claim is the type of “spousal defense” contemplated under section 6330. Neither he nor the Court has the ability toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007