CARDAMONE, Circuit Judge:
Individuals filing a joint tax return, often married couples, are jointly and severally liable for any tax liability found due and for any penalties and additions to tax. Congress has provided that such joint and several tax liability may sometimes be waived to avoid working a grave injustice to one spouse of the married couple, the so-called "innocent spouse." Anna Friedman (appellant or taxpayer) appeals from a November 30, 1993 decision...
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