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whether petitioner is entitled to relief from joint and several
liability pursuant to section 6015(b) or (f) for 1982, 1983,
1984, 1985, and 1986.2
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The first stipulation of facts, second stipulation of facts,
third stipulation of facts, and the attached exhibits are
incorporated herein by this reference. At the time she filed the
petition, petitioner resided in Buchanan, Michigan.
Petitioner
Petitioner is a high school graduate and a mother of four.
After high school, she worked full time doing “office work”.
Around 1960, petitioner married her first husband. She
worked full time during this marriage.
Petitioner’s marriage to her first husband lasted 7 years.
After their divorce, petitioner worked in order to support her
children.
1(...continued)
Court Rules of Practice and Procedure.
2 In her petition, petitioner sought relief pursuant to
sec. 6015(b) and (f). Accordingly, sec. 6015(c) is not in issue.
On brief, petitioner argues that she is entitled to sec.
6015 relief for 1981. In her petition, petitioner did not raise
her 1981 tax year; in her request for sec. 6015 relief,
petitioner did not raise her 1981 tax year; and, in the notice of
determination, respondent did not make a determination regarding
petitioner’s 1981 tax year. Accordingly, petitioner’s 1981 tax
year is not before the Court.
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