- 10 -
ordered the parties to file simultaneous briefs on the
computations. On April 29, 2004, however, we received the
parties’ signed stipulation of settlement instead.
The stipulation of settlement reflected that the parties had
agreed to a section 6015(c) allocation with respect to
petitioner’s and Mr. Bulger’s Federal income tax liabilities as
follows:
Joint tax liability Petitioner’s share
Year before allocation under sec. 6015(c)
1982 $7,896 -0-
1983 4,540 -0-
1984 10,542 -0-
1985 8,244 -0-
1986 10,894 -0-
1987 464 -0-
Total 42,580 -0-
The allocation of liability under section 6015(c) was made by
treating petitioner’s and Mr. Bulger’s SGE investment as a joint
investment, allocating 50 percent of the partnership items to
petitioner and 50 percent to Mr. Bulger in accordance with
section 6015(d)(1) and (3)(A), and adjusting the allocation, as
required by section 6015(d)(3)(B), to account for the tax benefit
that petitioner’s share of the partnership items provided to Mr.
Bulger on the joint returns. The parties further agreed that
petitioner was not entitled to relief from joint and several
liability under section 6015(b) or (f).
On May 7, 2004, we received and filed petitioner’s motion
for litigation and administrative costs. In her motion,
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