- 3 -
Year Deficiency
1984 $3,513
1986 71,974
1987 539,914
1988 527,851
1989 102,323
Respondent determined that petitioner is not entitled to
relief from joint and several liability under section 6015(b).
Petitioner timely filed a petition seeking review of respondent’s
determination. The issues we consider are: (1) Whether an
affirmative defense may be placed in issue under the principle of
implied consent, (2) whether the holding in an earlier opinion
results in respondent’s being collaterally estopped to deny that
petitioner did not know or have reason to know of an
understatement, and (3) whether petitioner is eligible for relief
from joint and several liability under section 6015(b).
FINDINGS OF FACT2
Petitioner resided in Windsor, Connecticut, at the time her
petition was filed. She completed high school and attended
college for 1 year. Petitioner married Gary Pierce on November
26, 1966, and they were married at all times pertinent to this
case. During the years at issue, Mr. Pierce was the sole
shareholder of Mary Catherine Development Corp. (Mary Catherine).
Initially, Mary Catherine purchased unimproved land, developed
2 The parties’ stipulation of facts is incorporated by this
reference.
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