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Karen L. Hawkins, for petitioner.
Thomas M. Rohall, for respondent.
COLVIN, Judge: Respondent determined that petitioner is not
entitled to relief from joint liability for tax under section
6015(f) for 1995. Petitioner filed a petition under section
6015(e)(1) seeking our determination whether she is entitled to
relief under section 6015(f).
The issues for decision are:1
1. Whether, in determining petitioner’s eligibility for
relief under section 6015(f), we may consider evidence introduced
at trial which was not included in the administrative record. We
hold that we may.
2. Whether petitioner is entitled to relief from joint
liability for tax under section 6015(f). We hold that she is.
Section references are to the Internal Revenue Code in
effect for the applicable years. Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
1 We have previously decided that we have jurisdiction in
this case. Ewing v. Commissioner, 118 T.C. 494 (2002).
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