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penalty under section 6662(a) in the amount of $1,079.1 After
concessions by the parties,2 the issue for decision is whether
petitioner is entitled to relief from joint and several liability
under section 6015. We hold that he is not.
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. Petitioner resided in Phoenixville, Pennsylvania, at the
time that his petition was filed with the Court.
Petitioner married Joyce Johnson Amankwah (now known as
Joyce Chester) in 1994. Petitioner and Ms. Chester have a son,
who was born in 1995.
Petitioner and Ms. Chester experienced financial
difficulties during 1995 and 1996. During 1995, Ms. Chester was
forced to take time away from her Schedule C business because of
complications resulting from her pregnancy. Ms. Chester's
Schedule C business was not profitable during 1995 (reporting a
1 All section references are to the Internal Revenue Code
in effect for the taxable year in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
2 Petitioner concedes that there was a failure to report a
taxable pension and annuities distribution in the amount of
$21,391 on the joint return that he filed for 1996 with Joyce
Johnson Amankwah. Petitioner also concedes an adjustment in the
amount of $14 relating to an early withdrawal penalty.
Respondent concedes an adjustment for interest income in the
amount of $20. The parties agree that an adjustment in the
amount of $347 for miscellaneous itemized deductions is purely a
mechanical matter. Finally, petitioner does not contest that the
penalty under section 6662(a) is applicable.
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