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relief under section 6015(b) or (c); and (2) whether respondent
abused his discretion in denying petitioner’s request for
equitable relief under section 6015(f).
Background
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner resided in Hope Mills, North Carolina, at the time she
filed the petition herein.
Petitioner was married to James L. Hyatt (Mr. Hyatt).
During the 1993 taxable year, petitioner was a housewife, and Mr.
Hyatt was a self-employed carpenter and partner of J.D. Trim
Company.
Petitioner and Mr. Hyatt filed a timely Federal income tax
return for the 1993 taxable year (1993 joint return). The 1993
joint return reported “total tax” of $4,175 and tax due of the
same amount. Petitioner and Mr. Hyatt did not remit any payment
with their return. On May 23, 1994, respondent accepted the 1993
joint tax return as filed and assessed the tax reported therein,
along with additions to tax under sections 6651(a)(2) and 6654 of
$39.70 and $166.34, respectively, and interest of $29.03.
Petitioner had overpayments of tax for the taxable years
1995 through 2001. Respondent applied these overpayments to
offset the outstanding tax liability associated with the 1993
joint return in the following manner:
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