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believed that the business expenses reported on the 1993 return
were overstated.
As previously mentioned, petitioner does not dispute
respondent’s application of section 6015(d)(3)(B) to allocate
$654 of the revised deficiency and $125 of the revised addition
to tax to both petitioner and intervenor. Accordingly, we hold
that petitioner is entitled to relief from joint and several
liability under section 6015(c) to the extent she did not receive
a tax benefit from intervenor’s erroneous business deductions.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011