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In their petition, petitioners dispute all of the
determinations made by respondent in the notice of deficiency,
and petitioners further argue that the statute of limitations
bars the assessment and collection of the taxes for each of the
years. Petitioner Donald J. Barnes (Mr. Barnes) and respondent
have settled all of the issues in this case as they pertain to
Mr. Barnes and have filed a stipulation of settled issues.
Petitioner Beverly A. Edwards (petitioner) has conceded that (1)
the adjustments in the notice of deficiency underlying the
amounts of the deficiencies are correct; (2) the statute of
limitations does not bar the assessment and collection of the
taxes in this case; and (3) petitioner is not entitled to a
deduction for a theft loss as asserted in the Second Amendment to
Petition. In the first Amendment to Petition, petitioner alleges
that she is entitled to relief from joint liability pursuant to
section 6015(b), (c), or (f), relief which respondent denied on
or about February 27, 2003.3 Thus, the remaining issues for
2(...continued)
6621(d). See TRA 1986 sec. 1511(c)(1)(A), 100 Stat. 2744;
Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 144(a), (c),
98 Stat. 682, 684. Sec. 6621(c) was repealed in 1989 with
respect to returns due after Dec. 31, 1989. Omnibus Budget
Reconciliation Act of 1989 (OBRA 1989), Pub. L. 101-239, sec.
7721(b), (d), 103 Stat. 2399, 2400.
3Respondent treated petitioner’s first Amendment to Petition
as petitioner’s request for relief under sec. 6015, and
respondent’s Appeals Office subsequently denied petitioner
relief.
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