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all Rule references are to the Tax Court Rules of Practice and
Procedure. The decisions to be entered are not reviewable by any
other court, and this opinion should not be cited as authority.
Respondent determined for 1999 a deficiency in William G.
Applegate's and Lucy S. Wang's Federal income tax of $7,176.1
The issues for decision are: (1) Whether petitioners are
entitled to deductions for employee business expenses; and
(2) whether Ms. Wang is entitled to relief from joint and several
liability on a joint return under section 6015.
The stipulated facts and the exhibits received into evidence
are incorporated herein by reference. At the time the petitions
in these cases were filed, both petitioners resided in Attica,
Indiana. The Court consolidated these cases for purposes of
trial, briefing, and opinion because they involve common
questions of law and fact.
Background
During taxable year 1999, petitioner William G. Applegate
(Mr. Applegate) and petitioner Lucy S. Wang (Ms. Wang) were
married to each other, and they presently remain so. Petitioners
timely filed a joint Form 1040, U.S. Individual Income Tax
Return, for 1999 which was prepared by Ms. Wang using information
1In the notice of deficiency, respondent allowed petitioners
a previously unclaimed child tax credit of $1,000.
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