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The sole issue for decision is whether petitioner is
entitled to relief from joint liability under section 6015. The
underlying deficiency determined by respondent in the notice of
deficiency is not at issue. Curtis T. Freeman (intervenor) is
the former spouse of petitioner and filed an intervention in this
proceeding pursuant to section 6015(e)(4) objecting to the
granting of relief to petitioner under section 6015. See Interim
Rule 325; King v. Commissioner, 115 T.C. 118 (2000).
At the time the petition was filed, and at the time the
notice of intervention was filed, the legal residence of
petitioner and intervenor was Hartsville, South Carolina.
Petitioner and intervenor were married during 1982. During
1981, intervenor had purchased approximately 100 acres of land at
Hartsville, South Carolina, and had begun a cattle-raising
activity that continued for several years, including the 1993 tax
year at issue. This activity commenced with one or two cows,
then grew to a herd of 25-30 cows with intermittent sales and
purchases of cows and calves along the way. It was by no means a
profitable activity, although intervenor had the expectation
that, over time, the activity would become profitable.
Intervenor allowed some of his neighbors to pasture their
livestock on the property, and the neighbors, in turn, assisted
to some degree in caring for intervenor’s livestock when
intervenor was frequently away from home in connection with his
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