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petitioner’s request for relief from joint and several liability
under section 6015(f) for those years.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue. All
amounts have been rounded to the nearest dollar.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. At the
time that the petition in this case was filed, petitioner resided
in Keyport, New Jersey.
Background
Petitioner and Frank Mazzilli (Mazzilli) were married in
1970. They had two children during their marriage. Between the
time that petitioner married Mazzilli and September 1992,
petitioner was a homemaker. Mazzilli became unemployed for a
period of approximately 17 weeks during 1992. As a result of
Mazzilli’s unemployment, petitioner and Mazzilli exhausted their
savings and could not make the monthly mortgage payments on their
home.
In order to help alleviate her family’s financial
difficulties, petitioner began to work as a receptionist at
Monmouth Associates in Internal Medicine, P.A., in September
1992. At the time that petitioner began working as a
receptionist, she completed Form W-4, Employee’s Withholding
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