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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue.
The issue for decision is whether petitioner is entitled to
relief from joint and several liability under section 6015(b),
(c), or (f) with respect to the above 1995 tax deficiency
determined by respondent. Intervenor does not claim a right to
such relief. Rather, intervenor testified at trial solely to
contest petitioner’s right thereto.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner resided in
Oklahoma City, Oklahoma.
In 1995, petitioner and intervenor worked at various jobs,
and intervenor was unemployed for approximately 5 months.
On January 19, 1996, petitioner and intervenor were
divorced.
On their 1995 timely filed joint Federal income tax return,
petitioner and intervenor reported taxable income of $29,775.
Petitioner and intervenor’s return was prepared by a tax return
preparer.
On audit, respondent determined that petitioner and
intervenor received $15,626 in additional income not reported on
their 1995 joint Federal income tax return, as set forth below:
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Last modified: May 25, 2011