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expenses totaling at least $1,600 for several items she had not
listed for 2001 or 2003, such as flood insurance ($125), payments
on a home equity loan ($250), credit card payments ($900), dry
cleaning ($80), personal care services (hair and nails) ($115-
$140), telephone, cable, and Internet service ($160), Federal
income and Social Security taxes, and State income tax.
In 2005, petitioner had no collectibles, art, stock,
annuities, life insurance with cash value, savings bonds, savings
account, or any other accounts with financial institutions other
than her section 401(k) retirement account.
As of January 7, 2003, petitioner and intervenor owed tax,
penalties, and interest in the amount of $27,626.39 for 1992,
$34,170.77 for 1993, $21,804.15 for 1994, $2,719.74 for 1995, and
$11,351.78 for 1996 for a total of $97,668.83.
OPINION
A. Background
If husband and wife file a joint Federal income tax return,
they are jointly and severally liable for the tax due. Sec.
6013(d)(3); Butler v. Commissioner, 114 T.C. 276, 282 (2000).
However, a spouse may qualify for relief from joint liability
under section 6015(b) or (c) if various requirements are met.
The parties agree that petitioner does not qualify for relief
under section 6015(b) or (c).
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