Alicia M. Elias - Page 3

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               Respondent determined a deficiency of $7,977 in petitioner’s           
          Federal income tax for the year 1999.  The sole issue for                   
          decision is whether petitioner is entitled to relief from joint             
          liability under section 6015 for 1999 Federal income tax.                   
               Some of the facts were stipulated.  Those facts, with the              
          exhibits annexed thereto, are so found and are made part hereof.            
          Petitioner’s legal residence at the time the petition was filed             
          was Pismo Beach, California.                                                
               Petitioner married Lee E. Elias (Mr. Elias) in May 1992.               
          They were divorced in the latter part of 2002.  They had two                
          children of their marriage.  Petitioner and Mr. Elias filed a               
          joint Federal income tax return for the year at issue, 1999.  In            
          the notice of deficiency, which was issued jointly to petitioner            
          and Mr. Elias, respondent determined a deficiency of $7,977 in              
          Federal income tax for 1999.  The deficiency is essentially based           
          on the disallowance of deductions for various Schedule C, Profit            
          or Loss From Business, expenses claimed on the 1999 return in               
          connection with the self-employed activity of Mr. Elias as an               
          agent for State Farm Insurance (State Farm).  Petitioner was not            
          involved in this activity, although both petitioner and Mr. Elias           
          had been engaged with State Farm in different capacities from the           
          time of their marriage.  During 1999, petitioner was employed as            
          a claims adjuster for State Farm.  In the latter part of 1999,              
          Mr. Elias discontinued his insurance agency business to become an           






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