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On February 11, 2003, respondent’s answer to petitioner’s
petition was filed. In his answer, respondent denied, without
qualification, the representation in subparagraph 6.p. and denied
the representations in subparagraphs 6.q. and r. “for lack of
knowledge or information.”
On February 23, 2004, this case was called for hearing
during the Seattle, Washington, trial session. The parties
reported that they believed they had a basis for settlement but
were awaiting final Government approval. The case was scheduled
for recall on March 2, 2004. At the recall, the parties reported
that the case had been settled and requested until April 1, 2004,
to submit a signed decision document. On April 2, 2004, the
parties submitted a signed decision document, which we filed as a
stipulation of settled issues. The stipulation of settled issues
reflected that the parties had agreed to a section 6015(c)
allocation with respect to petitioner’s and Mr. Foy’s 1981-1986
income tax liabilities as follows:
Joint tax liability Petitioner’s share
Year before allocation under sec. 6015(c)
1981 $22,995.36 -0-
1982 22,461.15 -0-
1983 24,280.00 -0-
1984 8,057.93 $51.46
1985 14,902.52 -0-
1986 10,607.08 -0-
Total 103,304.04 51.46
The allocation of liability under section 6015(c) was made by
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