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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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