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is entitled to relief under section 6015(b) or (c); and (2)
whether respondent abused his discretion in denying petitioner’s
request for equitable relief under section 6015(f).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
At the time the petition in this case was filed, petitioner
was a resident of Colorado Springs, Colorado.
Petitioner was married to Charles V. Moore (Mr. Moore) when
they jointly filed a Federal income tax return for 1992 (1992
joint return). Petitioner’s income for 1992 was $14,553, and her
withholding was $1,282. Mr. Moore’s income in 1992 was $39,064,
and his withholding was $334. The tax liability shown on the
1992 joint return was $7,267, and the net tax due after
subtracting credits and withholdings was $5,172. The $5,172 net
tax due was not paid when the 1992 joint return was filed.
Petitioner and Mr. Moore divorced in 1994.
Respondent applied petitioner’s overpayments from her tax
returns for 1993-2000, totaling $10,494, as offsets against
unpaid tax liabilities for 1987 and 1990-92. As relevant here,
on March 24, 1997, respondent began applying overpayments from
petitioner’s tax accounts to the balance owed on the joint
liability for 1992. On April 5, 1999, respondent also applied
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