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Respondent issued to petitioner a Final Notice determining
that petitioner was not entitled to allocate the deficiencies for
1989 and 1990 under section 6015(c). Petitioner timely filed her
Petition, and then Fred L. Nubin (intervenor) filed a Notice Of
Intervention. After a concession by respondent that petitioner
is entitled to relief from joint and several liability under
section 6015(c), this Court must decide whether respondent erred
in granting relief to petitioner under section 6015(c).
Most of the facts in this case have been stipulated and are
so found. Petitioner resided in Los Angeles, California, at the
time she filed her petition. Intervenor resided in Thomaston,
Georgia, at the time of the filing of the Notice of Intervention.
On March 19, 1976, petitioner and intervenor were married.
Petitioner was 34 years old, and intervenor was 50 years old at
the time of their marriage. In 1978, a daughter was born to
petitioner and intervenor.
Intervenor started the business activity, Fred Nubin
Building Maintenance, prior to the marriage. The business
provided janitorial services. During their marriage, intervenor
operated the business.
During the 1989 and 1990 taxable years in issue, petitioner
and intervenor were married and living together. During 1989 and
1990, petitioner was not employed on a full-time basis.
Petitioner and intervenor’s divorce was made final on March 3,
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