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from joint and several income tax liability under section 6015.1
Respondent determined that petitioner is not entitled to relief
from joint and several liability under section 6015, and
petitioner timely filed a petition seeking review of respondent’s
determination. The issue presented for our consideration is
whether petitioner is eligible for relief from joint and several
liability under subsections (b) or (c) of section 6015.
FINDINGS OF FACT2
Petitioner Andrew J. Zoglman resided in Sacramento,
California, at the time his petition was filed. Intervenor Kathy
E. Morrison (Ms. Morrison) also resided in Sacramento,
California, at the time she filed a Notice of Intervention.
Petitioner and Ms. Morrison were married on November 19, 1988.
Ms. Morrison filed for a dissolution of marriage on March 7,
1996, and a judgment of dissolution of marriage was entered on
November 20, 1997.
During 1993, while petitioner and Ms. Morrison were still
married, Ms. Morrison applied for Social Security benefits
(benefits) at the insistence of petitioner. Initially, Ms.
Morrison’s application was denied. During the following 2 years
1All section references are to the Internal Revenue Code in
effect for the year at issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
2The parties’ stipulation of facts is incorporated by this
reference.
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