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return to include the Form 1099 income she received from
Sporthouse.
On January 5, 1997, petitioners’ divorce became final.
Respondent mailed each petitioner a notice of deficiency for
1995 and a notice of determination concerning relief from joint
and several liability under section 6015 (notice of
determination).
In the notice of deficiency, respondent determined the
following adjustments: (1) Disallowance of a $7,796 Schedule C
loss of Mr. Weiler, (2) an increase of $15,315 in Schedule C
gross receipts of Ms. Weiler, (3) allowance of $9,046 in Schedule
C expenses for Ms. Weiler, (4) an increase of $886 in self-
employment tax, (5) allowance of a $443 deduction for self-
employment tax, (6) disallowance of $4,841 in itemized deductions
(unreimbursed employee expenses) of Mr. Weiler, (7) an increase
of $2 in alternative minimum tax, and (8) an $885.60 section 6662
penalty.
In the notice of determination, respondent determined that
neither petitioner qualified for relief from joint and several
liability pursuant to section 6015(b), (c), or (f) for 1995.
OPINION
This is a messy and somewhat convoluted case. Essentially,
however, the case boils down to the following: (1) Mr. Weiler
seeks relief pursuant to section 6015(b) and (c) from the items
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