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for their taxable year 1995 and to the immediate assessment and
collection of a deficiency of $9,719 in Federal income tax, a
penalty of $486, and interest as provided by law. On November
23, 1998, respondent assessed those amounts as well as interest
accruals thereon. (We shall refer to those assessed amounts as
well as interest as provided by law accrued after November 23,
1998, as petitioner’s unpaid liability for 1995.)
Petitioner did not enter into an installment agreement or
other arrangement to pay petitioner’s unpaid liability for 1995.
Nor did petitioner at any time attempt to borrow money on an
unsecured or secured basis in order to pay petitioner’s unpaid
liability for 1995.
On March 26, 1999, petitioner filed with respondent Form
8857, Request for Innocent Spouse Relief (And Separation of
Liability and Equitable Relief), with respect to petitioner’s
unpaid liability for 1995. (We shall refer to Form 8857 that
petitioner filed with respondent as petitioner’s Form 8857.)
Petitioner attached the following statement to petitioner’s Form
8857:
TO WHOM IT MAY CONCERN:
I am submitting this form because I am qualified
in every way for equitable relief.
I and my spouse have no community property. What
property I do have is an inheritance from my parent’s
estate.
My husband runs his own business and is self-
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