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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 to
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