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was repealed and replaced by sec. 6015, I.R.C.
Subsequently, W filed administrative elections for relief
pursuant to sec. 6015(b) and (c), I.R.C. R made a full
concession of W’s liability under sec. 6015(c), I.R.C., but
made no determination under sec. 6015(b), I.R.C. W seeks
judicial determination of her entitlement to relief under
sec. 6015(b), I.R.C.
1. Held: for taxable year 1989, respondent’s determination
of H’s unreported income through use of the net worth method
is not sustained.
2. Held: for taxable year 1990, respondent’s determination
of H’s unreported income through use of the net worth method
is modified.
3. Held: for taxable year 1990, respondent having fully
conceded W’s tax liability pursuant to her election under
sec. 6015(c), I.R.C., the question of her entitlement to
relief under sec. 6015(b), I.R.C. is moot.
Ramsey R. Taylor and G. Norris Watson, for petitioner in
docket No. 8691-97.
Howard B. Teller, for petitioner in docket No. 15040-97.
Richard A. Stone, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge: In these consolidated cases, respondent
determined deficiencies, additions to tax, and an accuracy-
related penalty in petitioners’ Federal income taxes as follows:
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