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relief from liability pursuant to section 6015(b), (c), or (f)
for 1982 through 1986 (notice of determination). The notice of
determination listed the following amounts of tax7 outstanding:
$5,454 for 1982, $2,593 for 1983, $7,207 for 1984, $56,081 for
1985, and $1,745 for 1986.
Petitioner’s Financial Status
On February 28, 2003, petitioner and Mr. Ellison signed a
Form 433-A, Collection Information Statement for Wage Earners and
Self-Employed Individuals. The Form 433-A contained the
following statements: Petitioner and Mr. Ellison owned the home
that they purchased in June 1989 for $97,000, with a current
value of $150,000, a loan balance of $123,463, and a monthly
payment totaling $1,015; they had no dependents they could claim
on their tax return; they had two checking accounts and one
savings account at Monroe Bank & Trust with a total balance of
$4,398. Their investments (Form 433-A investments) included:
(1) Monroe Bank & Trust (401k) with a current value of $30,362;
(2) Fidelity-IISI, Inc. (401k) with a current value of $17,329;
(3) Fidelity-Ford Tesphe (401k) with a current value of $44,917;
(4) Fidelity Investments (IRA-Pam) with a current value of
$2,526; and (5) 266 shares of Monroe Bank & Trust with a current
value of $2,979. They had available credit of $15,420 from Key
Bank and they had life insurance with a current cash value of
7 These amounts included interest.
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