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Background
Mr. Freeman was previously married to petitioner, and he and
petitioner filed a joint return for 1993, which is the year in
issue. Although Mr. Freeman is not a petitioner in this case, he
objects to petitioner’s claim for relief from joint liability.
At the time the petition was filed, petitioner was a
resident of Hartsville, South Carolina. At the time Mr. Freeman
filed his motion, he was also a resident of Hartsville, South
Carolina.
During 1993, petitioner and Mr. Freeman were married to each
other. They separated sometime during 1993 and, in May 1995,
they were divorced. Their joint Federal income tax return for
1993 included a Schedule C, Profit or Loss From Business, for a
farming activity. The reported gross income from this activity
was $802, the claimed expenses totaled $28,199, and the reported
net loss was $27,397. Respondent disallowed the $27,397 loss on
the ground that the farming activity was not engaged in for
profit. There were other adjustments to the return that flowed
from the disallowed loss. On December 23, 1996, respondent
issued separate notices of deficiency to petitioner and Mr.
Freeman. The deficiency shown in each notice was $7,781.
Petitioner filed a timely petition, but Mr. Freeman did not.
1(...continued)
Rules of Practice and Procedure.
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