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On May 22, 2006, petitioner timely filed a petition with
this Court for relief from joint and several liability with
regard to the entire amount of the above tax deficiencies
relating to the Hoyt partnership investments in which Glenn had
invested.
Shortly before trial, respondent agreed that petitioner
qualified for partial relief from joint liability under section
6015(c) for each year in issue, reducing the tax deficiency for
which petitioner is allegedly liable for each year by
approximately two-thirds.
Since her divorce in 2000, petitioner has timely filed
separate individual Federal income tax returns, and no tax
deficiencies for years subsequent to 1994 have been determined by
respondent against petitioner.
Petitioner has since remarried, and petitioner and her
current husband earn approximately $100,000 a year, of which
petitioner earns approximately $60,000.
OPINION
Generally, taxpayers filing joint Federal income tax returns
are jointly and severally liable for all taxes due. Sec.
6013(d)(3). However, relief from joint liability may be
available in circumstances described in section 6015(b), (c), and
(f).
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Last modified: November 10, 2007