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6015, and petitioner timely filed a petition seeking review of
respondent’s determination. The issue presented is whether
petitioner is eligible for additional relief from joint and
several liability under section 6015(b).2
Background
The parties submitted this case fully stipulated pursuant to
Rule 122. The stipulation of facts is incorporated herein by
this reference. Petitioner resided in Hobbs, New Mexico, when
the petition in this case was filed.
Petitioner was married to Domingo P. Aranda (Mr. Aranda)
during the taxable years at issue. Petitioner and Mr. Aranda
filed joint Federal income tax returns for 1984, 1985, and 1986.
In 1988, Mr. Aranda was arrested for drug violations and
sentenced to serve 24 years in prison. Petitioner was not
charged with any criminal offense. On May 12, 1988, respondent
made jeopardy assessments against petitioner and Mr. Aranda for
1984, 1985, and 1986 in the following amounts:
2In the stipulation of facts, petitioner asserted relevancy
objections with respect to Exhibits 4-R and 5-R. Because
petitioner’s arguments for relief under sec. 6015(b) rely solely
on the notice of determination, we sustain petitioner’s
objections to the exhibits.
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