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Abstract

Like numerous women every year, Elizabeth Cockrell recently learned a difficult lesson in tax law. Unbeknownst to many taxpayers, a husband and wife who file a joint return are jointly and severally liable for any taxes due with respect to that return. Elizabeth and John Crowley were married in 1979, separated in 1982, and divorced in 1983. In December, 1980, Elizabeth was hired as a stockbroker trainee in New York; she subsequently passed the "series seven" stockbroker examination and obtained her stockbroker license. John was a partner in three partnerships engaged in commodities straddle transactions. As an employee of a trading corporation, John arranged transactions for investors seeking tax-sheltered investments. Like most married couples, John and Elizabeth fied joint income tax returns during their marriage.

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