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On February 2, 1999, petitioner filed amended petitions
seeking entitlement to relief from joint and several liability
under section 6015. In her amended petitions, petitioner did not
dispute the accuracy of the deficiencies, additions to tax, and
penalties contained in the notices of deficiency. On March 31,
1999, respondent filed his answers to petitioner’s amended
petitions. In his answers to the amended petitions, respondent,
on the assumption that petitioner had made a valid election with
respect to the benefits of section 6015, conceded that, pursuant
to section 6015(c), petitioner was not liable for any deficiency
associated with unreported income of $283,928, $29,924, $94,648,
and $82,053, respectively for the years 1987 through 1990.
Respondent also conceded that petitioner was entitled to relief
from joint and several liability under section 6015(c) for 1990
with respect to the following adjustments: (1) Capital gain
income of $11,919; (2) income of $82,053 on Schedule C, Profit or
Loss From Business; and (3) all but $48.50 of interest income
which was part of a $4,847 adjustment.
On June 6, 2000, respondent and Mr. Rowe entered into
stipulations of agreed issues. In the stipulations, Mr. Rowe
conceded the accuracy of all the determinations respondent made
in the notices of deficiency.
The trial in these consolidated cases was held on February
9, 2001. At that time, the parties filed a stipulation of facts
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