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With respect to Ms. Collier’s contention that she did not
jointly file a tax return with Mr. Collier for taxable year 1990
or taxable year 1991, the parties stipulated that Ms. Collier and
Mr. Collier filed their tax returns for those years on April 15,
1991, and April 15, 1992, respectively. Ms. Collier argues that
we should disregard that stipulation. In support of that argu-
ment, Ms. Collier asserts:
A visual inspection of the 1990 and 1991 returns
shows that petitioner did not sign the 1990 return and
that the “Sandrus Collier” signature appearing on the
1991 return is different from the signature on the 1987
and 1989 returns. Both parties here must have made a
mutual mistake when entering into the stipulation
* * *.
We shall not disregard the parties’ stipulations of fact
that Ms. Collier and Mr. Collier filed their tax return for each
of the taxable years 1990 and 1991 unless justice requires us to
do so. Rule 91(e). We conclude that justice does not require us
to disregard those stipulations.
Assuming arguendo that Ms. Collier did not sign the 1990
joint return and the 1991 joint return, on the instant record, we
find that any such facts are not contrary to the parties’ stipu-
lations of fact that Ms. Collier and Mr. Collier filed their tax
13(...continued)
were to find, contrary to the parties’ stipulation, that Ms.
Collier did not file tax returns for 1990 and 1991 jointly with
Mr. Collier, Ms. Collier would not be entitled for those years to
relief under sec. 6015(f). See sec. 6015; Rev. Proc. 2000-15,
sec. 4.01(1), 2000-1 C.B. 447, 448.
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