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petitioners’ 1995 Federal income taxes. Respondent also
determined that neither petitioner qualified for relief from
joint and several liability pursuant to section 6015(b), (c), or
(f). After concessions,2 the issue for decision is each
petitioner’s entitlement to relief from joint and several
liability pursuant to section 6015(b) and (c) for 1995.3
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
the petitions, petitioners both resided in Westlake Village,
California.
Sometime before 1990, petitioners married. Petitioners
filed joint income tax returns every year they were married.
During the last half of 1994 and all of 1995, petitioners lived
apart.
1(...continued)
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
2 Petitioners concede the adjustments determined in the
notice of deficiency. Respondent and petitioners have made
concessions regarding petitioners’ entitlement to relief pursuant
to sec. 6015(b) and (c). For purposes of clarity, those
concessions are discussed infra.
3 In their petitions, petitioners sought relief pursuant to
sec. 6015(b) and (c). Accordingly, sec. 6015(f) is not in issue.
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