-5-
any evidence to substantiate the claimed charitable contributions
deducted on their joint 2002 Federal income tax return. In fact,
Butler and Schwendeman testified that she and he, respectively,
did not make charitable contributions in 2002. We sustain
respondent’s deficiency determination of $3,672.
B. Relief Under Section 6015
Spouses filing a joint Federal income tax return are
generally jointly and severally liable for tax found to be owing.
Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C. 276, 282
(2000). However, it is possible for an individual filing a joint
return to be relieved of such joint and several liability.
Section 6015 prescribes three types of relief: (1) Full or
apportioned relief under section 6015(b), (2) proportionate
relief under section 6015(c), and (3) equitable relief under
section 6015(f). Butler claims entitlement to one or more of
these types of relief. Except as otherwise provided in section
6015, Butler bears the burden of proving that claim. See Alt v.
Commissioner, 119 T.C. 306, 311 (2002), affd. 101 Fed. Appx. 34
(6th Cir. 2004); see also Rule 142(a)(1).
To qualify for relief under section 6015(b), a requesting
spouse needs to satisfy the requirements of section 6015(b)(1).
Under section 6015(b)(1), relief may be granted under 6015(b) if
the following factors are met: (1) A joint return has been made
for the taxable year; (2) on such return there is an
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