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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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