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parties’ arguments on brief did not address these settled issues,
which leads us to the conclusion that those issues were settled
well before the actual filing of the stipulation. Accordingly,
petitioner has failed to establish that respondent’s position
with respect to these conceded issues was not substantially
justified. See, e.g., Lozon v. Commissioner, T.C. Memo. 1997-
537.
C. Respondent’s Denial of Relief Under Section 6015
Petitioner made valid elections for relief from joint and
several liability under section 6015(b), (c), and (f). Before
and after trial, respondent conceded that petitioner was entitled
to partial relief under section 6015. We have already held that
respondent’s position with respect to these concessions was
substantially justified. Respondent denied petitioner relief
under section 6015(b), (c), and (f) with respect to the remaining
deficiencies, additions to tax, and penalties. In Rowe I, we
relied on section 6015(c) and (f) and held that petitioner was
entitled to relief from joint and several liability for the
remaining portions of the disputed deficiencies, additions to
tax, and penalties. Petitioner argues that respondent was not
substantially justified in denying her relief under section
6015(b), (c), and (f) with respect to the issues we decided in
her favor.
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