Dorene Bulger - Page 10

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          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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