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The case arises from petitioner’s election to seek relief
from joint and several liability under section 6015 for Federal
income tax for 1997. Respondent issued to petitioner a notice of
determination that she is not entitled to relief under section
6015(b), (c), or (f).
Respondent now concedes that petitioner is entitled to
relief under section 6015(b) and to a refund, under section
6015(g), of an overpayment of $437.90 for 2001 that was offset
against a deficiency assessment for 1997. The issue remaining
for decision is whether petitioner is entitled to a refund of an
overpayment of tax for 2000 that was offset against the
deficiency assessment for 1997.
Background
The exhibits received into evidence are incorporated herein
by reference. At the time the petition in this case was filed,
petitioner resided in Orlando, Florida.
Petitioner and her then husband timely filed a joint Federal
income tax return for 1997. In 2000, respondent issued a
statutory notice of deficiency to petitioners, determining
additional tax due for 1997. No petition was filed with the
Court for a redetermination of the proposed deficiency, and the
tax was subsequently assessed.
Certified transcripts introduced by respondent show that on
February 19, 2001, respondent captured petitioner’s overpayment
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