- 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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