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section 6015(e)(1) for relief from joint and several liability.
Specifically, petitioner seeks a refund pursuant to respondent’s
determination that he is entitled to relief under section 6015(c)
with respect to taxable year 1993.
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Wilmington, Delaware, on the date the petition was filed in this
case.
There are no relevant disputed facts in this case.
Petitioner and his former spouse filed a joint Federal income tax
return for taxable year 1993. Petitioner was subsequently
divorced from his spouse, and he has lived alone and has been
filing separate returns since 1994.
In 1996, respondent assessed a deficiency of $15,479, plus
interest, relating to petitioner’s taxable year 1993. This
deficiency was never paid directly by petitioner to respondent.
On February 23, 1998, a Federal income tax overpayment by
petitioner of $6,842 with respect to his 1997 taxable year was
applied to the 1993 liability. On April 12, 1999, a 1998
overpayment by petitioner of $9,891 was applied to the remaining
1993 liability.2
2The amounts credited to petitioner’s 1993 tax liability
exceed the deficiency amount. Respondent’s counsel stated at
(continued...)
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