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tax attributable to certain erroneous items on a return; (2)
section 6015(c) provides relief for a portion of an
understatement of tax to taxpayers who are separated or divorced;
and (3) section 6015(f) more broadly confers on the Secretary the
discretion to grant equitable relief to taxpayers who otherwise
do not qualify under section 6015(b) or (c). See also sec.
6015(e).
Except as otherwise provided in section 6015, the taxpayer
bears the burden of proof to show his or her entitlement to
relief. Rule 142(a); Alt v. Commissioner, 119 T.C. 306, 311
(2002), affd. 101 Fed. Appx. 34 (6th Cir. 2004).
B. Mr. Munsinger
Mr. Munsinger jointly filed the petition giving rise to the
instant action, and he signed a stipulation of facts. However,
he did not appear in person at trial to testify.
Mr. Munsinger’s stipulation of facts did not address the
issue before us, namely, his request for relief from joint and
several liability. It merely conceded the deficiency stemming
from, in part, his own receipt of gross income from wages in the
amount of $5,317.
As noted above, the taxpayer bears the burden of
establishing entitlement to relief. Rule 142(a); Alt v.
Commissioner, supra. Mr. Munsinger has not met his burden, and
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