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entered is not reviewable by any court, and this opinion should
not be cited as authority.
Respondent determined that petitioner is not entitled to
relief from joint liability for tax under section 6015(b), (c),
or (f) for 1999. Petitioner filed a petition under section
6015(e)(1) seeking review of respondent’s determination.
Petitioner’s former wife (intervenor) filed a notice of
intervention under Rule 325(b) and opposes such relief.
Petitioner prepared and petitioner and intervenor signed and
filed a joint return for 1999 in which they correctly reported
the amount of tax but overstated their Federal income tax
withholding by $2,000. Respondent did not immediately discover
the error and issued a $1,491 refund to petitioner and intervenor
for 1999. Petitioner alone benefited from the refund.
The sole issue for decision is whether, under section
6015(b), (c), or (f), petitioner is entitled to relief from
repaying the erroneous refund for 1999.2 We hold that he is not.
2 We derive this statement of petitioner’s position from the
petition. Petitioner also claims generally that he should be
relieved from joint and several liability for 1999. However, he
has presented no argument for relief from liability other than
for the liability arising from the erroneous refund for 1999.
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