Kirsten Nelson, a.k.a. Kirsten E. Hillstrom - Page 2

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          is entitled to relief under section 6015(b) or (c); and (2)                 
          whether respondent abused his discretion in denying petitioner’s            
          request for equitable relief under section 6015(f).                         
                                  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 the petition in this case was filed, petitioner            
          was a resident of Colorado Springs, Colorado.                               
               Petitioner was married to Charles V. Moore (Mr. Moore) when            
          they jointly filed a Federal income tax return for 1992 (1992               
          joint return).  Petitioner’s income for 1992 was $14,553, and her           
          withholding was $1,282.  Mr. Moore’s income in 1992 was $39,064,            
          and his withholding was $334.  The tax liability shown on the               
          1992 joint return was $7,267, and the net tax due after                     
          subtracting credits and withholdings was $5,172.  The $5,172 net            
          tax due was not paid when the 1992 joint return was filed.                  
               Petitioner and Mr. Moore divorced in 1994.                             
               Respondent applied petitioner’s overpayments from her tax              
          returns for 1993-2000, totaling $10,494, as offsets against                 
          unpaid tax liabilities for 1987 and 1990-92.  As relevant here,             
          on March 24, 1997, respondent began applying overpayments from              
          petitioner’s tax accounts to the balance owed on the joint                  
          liability for 1992.  On April 5, 1999, respondent also applied              






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