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Medi-Task is allocated to petitioner Sarah K. Hawthorne
(Hawthorne) for purposes of computing self-employment tax for
1994. We hold that it is.
2. Whether petitioners may deduct expenses relating to
their rental cabins in 1994. We hold that they may not.
3. Whether petitioner Fredie Lynn Charlton (Charlton) is
entitled to relief from joint and several liability under section
6015(b) for the income tax deficiency arising from petitioners’
1994 joint return. We hold that he is not.
4. Whether petitioner Fredie Lynn Charlton qualifies for
limitation of liability under section 6015(c) for the income tax
deficiency arising from petitioners’ 1994 joint return. We hold
that he does to the extent described below.
5. Whether we have jurisdiction to review whether relief
is available to petitioner Sarah K. Hawthorne under section
6015(f). We hold that we do. Thus, we will delay entry of
decision to permit Hawthorne and respondent to report on the
status of Hawthorne’s application for relief under section
6015(f), and if relief is denied, to file a motion as part of
this docketed case requesting our review of the Secretary’s
denial.
Section references are to the Internal Revenue Code in
effect for 1994. Rule references are to the Tax Court Rules of
Practice and Procedure.
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