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and a first supplemental stipulation of facts. The concessions
respondent made in his answers to petitioner’s amended petitions
were contained in the stipulations. During the trial, petitioner
did not dispute the accuracy of respondent’s determinations.
Rather, petitioner presented evidence in support of her argument
that she was not liable for the deficiencies, additions to tax,
and penalties because she was entitled to relief from joint and
several liability under section 6015.
On May 7, 2001, respondent and petitioner filed a
stipulation of settled issues. In the stipulation, petitioner
conceded that she was not entitled to relief from joint liability
for an $85 theft loss adjustment in 1987 and a $6,253 income
adjustment in 1990. Petitioner also conceded that she was not
entitled to relief from joint and several liability for $48.50 of
interest income, still in dispute, which was part of a $4,847
adjustment in 1990. Respondent conceded that petitioner was
entitled to relief from joint and several liability under section
6015(c) for a $6,282 rental income adjustment in 1990 and for
$112,979 of a $116,405 lump-sum distributions adjustment in 1990.
On brief, the parties presented arguments as to whether
petitioner was entitled to relief from joint and several
liability pursuant to section 6015 with respect to the following
omitted income and erroneous deduction items giving rise to
deficiencies: (1) Distribution proceeds from a retirement
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