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inequitable to hold the individual liable for any unpaid tax or
any deficiency (or any portion of either)”.
Mrs. Kosinski seeks relief under section 6015(b) for 1997.
Section 6015(b) provides, in pertinent part, as follows:
SEC. 6015(b). Procedures For Relief From
Liability Applicable to All Joint Filers.--
(1) In general.--Under procedures prescribed
by the Secretary, if--
(A) a joint return has been made for a
taxable year;
(B) on such return there is an
understatement of tax attributable to
erroneous items of 1 individual filing the
joint return;
(C) the other individual filing the
joint return establishes that in signing the
return he or she did not know, and had no
reason to know, that there was such
understatement;
(D) taking into account all the facts
and circumstances, it is inequitable to hold
the other individual liable for the
deficiency in tax for such taxable year
attributable to such understatement; and
* * * * * * *
then the other individual shall be relieved of
liability for tax (including interest, penalties,
and other amounts) for such taxable year to the
extent such liability is attributable to such
understatement.
The requirements of section 6015(b)(1) are stated in the
conjunctive. Accordingly, a failure to meet any one of them
prevents a requesting spouse from qualifying for the relief
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