WINTER, District Judge.
After her husband's fraudulent late filing of a joint return, and after her husband's death, can a spouse, who has no income but who joined her husband in filing a joint return, disavow the filing of the joint return so that liability for the entire tax is visited solely upon her deceased husband's estate? If not, can she, since the fraud was solely that of her husband, escape liability for the interest and penalty on the amount due? These...
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