Louise Demirjian - Page 2

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          for relief from joint and several liability under either section            
          6015(b) or section 6015(c) and (2) whether respondent abused his            
          discretion in denying petitioner’s request for relief from joint            
          and several liability under section 6015(f).                                
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the year in issue.  All             
          amounts have been rounded to the nearest dollar.                            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.  At the           
          time that the petition in this case was filed, petitioner resided           
          in New York, New York.                                                      
          Background                                                                  
               Petitioner married George Apostle (Apostle) on May 14, 1989.           
          On or about June 29, 1989, petitioner sold an apartment in New              
          York City (New York apartment) that she owned jointly as tenants            
          in common with John Demirjian, petitioner’s first husband.                  
          Petitioner realized a $564,000 gain on this sale.  Both                     
          petitioner and Apostle were under the age of 55 when the New York           
          apartment was sold.  Petitioner and Apostle were divorced on                
          September 22, 1994.  Apostle died in 2002.                                  
          The Original Joint Return                                                   
               On or about September 24, 1990, petitioner and Apostle filed           
          a joint Form 1040, U.S. Individual Income Tax Return, and                   






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