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petitioner is entitled to relief from joint and several liability
pursuant to section 6015(b), (c), or (f).1
FINDINGS OF FACT
Petitioner, a legal secretary and high school graduate, and
Mr. Orsino, who has a degree in bioengineering, married on
September 1, 1968. During their marriage, petitioner was
responsible for balancing their joint checking account and paying
the monthly bills, and Mr. Orsino was responsible for filing all
of their Federal tax returns.
Mr. Orsino worked for Betz Dearborne as a water treatment
specialist for several years prior to, and during, 1998. He quit
his job at Betz Dearborne in April or May 1998, but continued as
a consultant for 4 weeks. Mr. Orsino also performed water
treatment services for National Engineering & Repair Corp.
(National Engineering) in May and June of 1998 and deposited
compensation received from both companies in the joint checking
account. Petitioner was aware that Mr. Orsino performed services
for both Betz Dearborne and National Engineering.
Petitioner and Mr. Orsino separated sometime in July of
1998. Shortly before their separation, Mr. Orsino’s mother
provided Mr. Orsino with a $6,000 savings bond, which Mr. Orsino
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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