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with respect to tax matters, and that she relied on her husband
with respect to the 2002 tax return. She acknowledged, however,
that she had met with the tax return preparer, had provided
information to the tax preparer, and had signed her name and her
husband’s name to the 2002 return.
Discussion
Aside from the stipulated documents that had been presented
to respondent’s Appeals officer, petitioner presented no evidence
with respect to the disallowed deductions claimed on her 2002
Federal income tax return. She offered no reasonable cause that
would avoid the addition to tax under section 6651(a) for late
filing of the return. She addressed only her contention that her
former husband should be responsible for the deficiency.
Section 6015 provides for relief from joint and several
liability only in certain circumstances. Section 6015(b) applies
only if, among other things, there is an understatement of tax
attributable to erroneous items of the other individual filing
the joint return (Xavier White), and the person seeking relief
(petitioner) establishes that, in signing the return, she did not
know, and had no reason to know, that there was such an
understatement. Petitioner has failed to establish either of
those requirements. Her signature appears on the checks tendered
to substantiate the disallowed deductions, and she directly
participated in preparation of the joint return.
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Last modified: November 10, 2007