Pamela J. Ellison - Page 2

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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 Monroe, Michigan.                           
          Petitioner and Her Husband                                                  
               Petitioner has a high school education that, since 1991, she           
          has supplemented with some college courses in bank management.              
               Petitioner married Don Ellison (Mr. Ellison) in 1971.  As of           
          the date of trial, petitioner and Mr. Ellison were married and              
          living together.  Mr. Ellison is currently employed as an                   
          inspector at the Ford Motor Co.                                             
               From 1971 to 1988, petitioner mainly worked part-time jobs.            
          In 1986, however, she worked full time as a bank teller.  Since             
          1990, petitioner has worked full time as a collections supervisor           
          at a financial institution.                                                 



               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.           





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