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After concessions,1 the sole issue for decision is whether
petitioner wife is entitled to relief from joint and several
liability under section 6015(b)(1).2
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. References to petitioner in the singular are to
Penelope J. Von Kalinowski.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
their petition with the Court, petitioners were residents of Los
Angeles, California.
Petitioners jointly filed a Form 1040, U.S. Individual
Income Tax Return, for each of the taxable years at issue. With
respect to taxable year 1981, petitioners twice filed an amended
1 Without considering the application of the relief
provisions of sec. 6015 to petitioner Penelope J. Von Kalinowski,
petitioners concede deficiencies of $179,230 and $81,495 for tax
years 1981 and 1982, respectively. Respondent concedes the
additions to tax under sec. 6653(a)(1) and (a)(2).
2 Sec. 6015 was added by sec. 3201(a) of the Internal
Revenue Service Restructuring and Reform Act of 1998, Pub. L.
105-206, 112 Stat. 734. Sec. 6015 is effective with respect to
any tax liability arising after July 22, 1998, and any tax
liability arising on or before July 22, 1998, that is unpaid on
that date.
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