Theron R. Livingston, Sr. - Page 2




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               was repealed and replaced by sec. 6015, I.R.C.                           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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