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Respondent determined that petitioner was not eligible for
section 6015 relief from joint and several liability for 1995 and
1997.
After a concession by respondent as to petitioner’s
entitlement to section 6015 relief for 1997, the issue for
decision is whether petitioner also is entitled to section 6015
relief from joint and several liability for 1995.
Some of the facts in this case have been stipulated and are
so found. Petitioner resided in East Greenwich, Rhode Island, at
the time she filed her petition.
Petitioner separated from her husband, David Giles (Mr.
Giles), in 1995. Their divorce was final in 1998.
For 1995, petitioner and Mr. Giles jointly filed a Form
1040, U.S. Individual Income Tax Return. Mr. Giles was an
insurance adjuster, and petitioner was a marketing director. On
their Form 1040, petitioner and Mr. Giles reported $136,375
(rounded) in wage income. The Forms W-2, Wage and Tax Statement,
attached to the Form 1040, reflected income of $119,233.18 for
Mr. Giles and $17,142.09 for petitioner.
Petitioner’s actual income for 1995 was $47,652.08 as shown
on the two Forms W-2 issued by her employer. This $30,509.99
omission of petitioner’s income, shown on one of the Forms W-2,
gave rise to the tax liability for 1995.
On November 26, 1997, respondent issued to petitioner and
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