Estate of Keith L. Gurr - Page 4




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          6015(f).  Respondent and Keith L. Gurr (Mr. Gurr) opposed                   
          petitioner's claim.  However, in a posttrial reply brief,                   
          respondent conceded petitioner's entitlement to limited liability           
          relief under section 6015(c) to the extent of 50 percent of the             
          deficiencies attributable to three adjustments in the notice of             
          deficiency for 1992 and four notice of deficiency adjustments for           
          the year 1993 relating to certain real estate transactions.                 
          Respondent made no concession with respect to one adjustment in             
          the 1993 notice of deficiency relating to the taxable portion of            
          Social Security benefits received by petitioners that year.                 
          Given the concession of respondent, petitioner, nevertheless,               
          maintains her entitlement to total relief under section 6015(b),            
          (c), and (f).                                                               
               Some of the facts were stipulated.  Those facts, and the               
          annexed exhibits, are so found and are incorporated herein by               
          reference.  At the time the petition was filed, Mr. Gurr's legal            
          residence was Sandy, Utah, and petitioner's legal residence was             
          West Jordan, Utah.                                                          
               Petitioner and Mr. Gurr were married in 1952.  Their                   
          marriage lasted 43 years.  They separated on November 4, 1993,              
          and were divorced on August 29, 1995.  They had five children.              
          Petitioner had one other child from a prior marriage.                       
               Respondent issued separate notices of deficiency to                    
          petitioner and Mr. Gurr, and a joint petition was filed timely.             





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