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Respondent determined a deficiency in petitioner’s Federal
income tax for the taxable year 2000 of $668. The issues for
decision are: (1) Whether petitioner is entitled to relief under
section 6015(b) or (c); and (2) whether respondent abused his
discretion in denying petitioner’s request for relief from joint
and several liability 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 Lexington, North Carolina, at the time she
filed the petition herein.
Petitioner was married to Max Gilliam in 1992. In July
2000, Mr. Gilliam and petitioner separated. Petitioner remained
in the marital residence until sometime in 2001. Sometime in
2002 Mr. Gilliam and petitioner were divorced.
During the taxable year 2000, Mr. Gilliam received wages of
$18,034, and petitioner received wages from three separate
employers totaling $4,464. Petitioner filed a joint Federal
income tax return with Mr. Gilliam for the taxable year 2000
sometime in January 2001. The joint return was prepared by Mr.
Gilliam and signed by both petitioner and Mr. Gilliam. The
return reported wage income of $18,034. Attached to the return
were four Forms W-2, Wage and Tax Statement. One of the Forms W-
2, reflecting wages of $18,034, was issued to Mr. Gilliam. The
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