Diana Van Arsdalen, f.k.a. Diana Murray, Petitioner, and Stanley David Murray, Intervenor - Page 7

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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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