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petitioner was entitled to substantial relief under section
6015(c) for various income items. These concessions were
subsequently agreed to in the stipulation of facts and the first
supplemental stipulation of facts. Respondent’s concessions as
to these income items within 2 months of the filing of the
amended petitions were reasonable in light of the fact that
current section 6015 was a new statute raising interpretive
issues. See, e.g., White v. United States, 740 F.2d 836, 842
(11th Cir. 1984) (Government’s concession of issue 3 months after
issue raised was reasonable); Sokol v. Commissioner, supra at 765
n.10 (citing cases discussing reasonable amount of time within
which to investigate claims and concede issues); Livingston v.
Commissioner, supra (Commissioner entitled to take reasonable
amount of time after claim for relief from joint and several
liability to verify whether facts established that taxpayer was
entitled to such relief).
B. Respondent’s Concessions in Stipulation of Settled
Issues
On May 7, 2001, the parties filed a stipulation of settled
issues in which both respondent and petitioner conceded certain
issues related to petitioner’s entitlement to relief from joint
and several liability. Petitioner has not alleged specific facts
to establish why the delay in granting relief from the time the
petitions were filed until the date the stipulation of settled
issues was filed was not substantially justified. Indeed, the
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