Linda M. Weiler, a.k.a. Linda M. Krupnick - Page 2

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            petitioners’ 1995 Federal income taxes.  Respondent also                                    
            determined that neither petitioner qualified for relief from                                
            joint and several liability pursuant to section 6015(b), (c), or                            
            (f).  After concessions,2 the issue for decision is each                                    
            petitioner’s entitlement to relief from joint and several                                   
            liability pursuant to section 6015(b) and (c) for 1995.3                                    
                                          FINDINGS OF FACT                                              
                  Some of the facts have been stipulated and are so found.                              
            The stipulation of facts and the attached exhibits are                                      
            incorporated herein by this reference.  At the time they filed                              
            the petitions, petitioners both resided in Westlake Village,                                
            California.                                                                                 
                  Sometime before 1990, petitioners married.  Petitioners                               
            filed joint income tax returns every year they were married.                                
            During the last half of 1994 and all of 1995, petitioners lived                             
            apart.                                                                                      


                  1(...continued)                                                                       
            the Internal Revenue Code, and all Rule references are to the Tax                           
            Court Rules of Practice and Procedure.                                                      
                  2  Petitioners concede the adjustments determined in the                              
            notice of deficiency.  Respondent and petitioners have made                                 
            concessions regarding petitioners’ entitlement to relief pursuant                           
            to sec. 6015(b) and (c).  For purposes of clarity, those                                    
            concessions are discussed infra.                                                            
                  3  In their petitions, petitioners sought relief pursuant to                          
            sec. 6015(b) and (c).  Accordingly, sec. 6015(f) is not in issue.                           







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