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Held, further, P is not entitled to relief under
I.R.C. sec. 6015 for 1989 because she did not file a
joint return. Raymond v. Commissioner, 119 T.C. 191
(2002).
Held, further, pursuant to I.R.C. sec.
6015(b)(1)(D), P is not entitled to relief under I.R.C.
sec. 6015(b) for taxable years 1982 to 1988 because,
taking into account all facts and circumstances, it is
not inequitable to hold P liable for the deficiencies.
Held, further, pursuant to I.R.C. sec.
6015(c)(3)(A)(i), P is not entitled to relief under
I.R.C. sec. 6015(c) for taxable years 1982 to 1988
because P and H are still married, have not separated,
and remained members of the same household during the
12-month period preceding the filing of the election by
petitioner.
Held, further, R did not abuse his discretion in
denying P relief under I.R.C. sec. 6015(f) for taxable
years 1982 to 1988 because we held that, taking into
account all facts and circumstances, it is not
inequitable to hold P liable for the deficiencies under
I.R.C. sec. 6015(b)(1)(D).
Rosalinda E. Alt, pro se.
A. Gary Begun, for respondent.
VASQUEZ, Judge: This case arises from a request for relief
under section 60151 with respect to petitioner’s taxable years
1982 to 1989 (years at issue). The issues for decision are: (1)
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at all relevant times. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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