Jacquelyn Brown - Page 2




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          is entitled to relief from joint and several liability for those            
          years.                                                                      
               Respondent now concedes that petitioner is entitled to                 
          relief from joint liability for tax for 1989 and 1990, and for              
          tax arising from $2,923 of Hoffman J. Brown’s income in 1988.               
          After respondent’s concessions, the sole issue for decision is              
          whether respondent’s denial of petitioner’s request for relief              
          from the remainder of the 1988 tax liability was an abuse of                
          discretion.  We hold that it was not.                                       
               Unless otherwise specified, section references are to the              
          Internal Revenue Code in effect for the applicable years.                   
          References to Hoffman J. Brown (Brown) are to petitioner’s                  
          husband.  References to the Browns are to petitioner and Brown.             
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          A.   Petitioner, Her Husband, and Their Joint Tax Returns                   
               Petitioner resided in Baltimore, Maryland, when she filed              
          the petition in this case.  Brown was a minister at the Main                
          Street Baptist Church in Smithfield, Virginia, in 1988, 1989, and           
          1990.                                                                       
               Brown reported the income from his ministry on Schedules C,            
          Profit or Loss From Business, attached to his and petitioner’s              
          1988-90 returns.                                                            








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