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consolidated. In a stipulation of settlement, the parties agreed
to deficiencies of $265,255 for 1997 and zero for 1998. The sole
remaining issue in this case is whether petitioner Ione
McClelland (Ms. McClelland) is entitled to relief from joint and
several liability pursuant to section 6015(b)1 or, in the
alternative, under section 6015(f). Respondent concedes this
issue, but petitioner Eugene McClelland (Mr. McClelland) opposes
such relief. As explained herein, we find Ms. McClelland is
entitled to relief under section 6015(b).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. During the tax years in issue,
petitioners resided in Red Wing, Minnesota.
Ms. McClelland’s General Background
Ms. McClelland was born on May 15, 1940, and graduated from
high school in May 1958. Ms. McClelland married Mr. McClelland
on February 14, 1959.
In the summer of 1959, Ms. McClelland was trained as a
flight attendant. However, during 1959 and early 1960, she
worked as a waitress. From sometime in 1960 until 1967, she
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect during the years in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
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