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of the taxable years 1989, 1991, 1992, and 1993 with respect to
American Supply and MFS Lifetime.12
On December 16, 1997, petitioner and Mr. Monsour filed a
petition (petition for the taxable years at issue) in the Court
with respect to the notice for the taxable years at issue. (We
shall refer to the case that petitioner and Mr. Monsour commenced
when they filed the petition for the taxable years at issue as
the case for the taxable years at issue.) In that petition,
petitioner and Mr. Monsour did not make a claim that petitioner
is entitled to relief under section 6013(e) with respect to any
of the taxable years at issue. At no time while the case for the
taxable years at issue was pending in the Court, including during
the period July 22 to October 8, 1998, the date on which, pursu-
ant to the agreement of the parties, the Court entered a decision
for the taxable years at issue (discussed below), did petitioner
make a claim that she is entitled to relief from joint and sev-
eral liability with respect to any of those taxable years.
Mr. Winschel represented petitioner and Mr. Monsour in the
case for the taxable years at issue. Mr. Laubach represented
respondent in that case.
At a time not disclosed by the record before June 8, 1998,
12The record does not establish the nature and the respec-
tive amounts of respondent’s determinations with respect to
American Supply and MFS Lifetime. Nor does the record establish
to which of the taxable years 1989, 1991, 1992, and 1993 those
determinations pertain.
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