- 12 - 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, thePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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