Barbara A. Owen - Page 9

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          r. based on lack of knowledge or information and denied the                 
          representation in subparagraph q. without qualification.                    
               On February 23, 2004, this case was called for hearing                 
          during the Court’s Seattle, Washington, trial session.  The                 
          parties reported that they believed they had reached a basis for            
          settlement, and the case was scheduled for recall on March 2,               
          2004.  At the recall, the parties indicated on the record that              
          they had reached an agreement on the deficiencies but had not               
          settled the issue of penalties.  On March 3, 2004, the parties              
          reported that the case had been settled and requested until April           
          19, 2004, to submit a signed decision document.  In addition, the           
          parties agreed that the Court did not have jurisdiction over the            
          proposed addition to tax under section 6651(a)(3), and petitioner           
          stated on the record that she did not concede that the penalty              
          should be imposed.                                                          
               After issuing an order on April 26, 2004, extending the time           
          for the parties to submit a signed decision document, we filed              
          the parties’ signed stipulation of settlement on May 10, 2004.              
          The stipulation of settlement reflected that the parties had                
          agreed to a section 6015(c) allocation with respect to                      
          petitioner’s and Mr. Owen’s Federal income tax liabilities as               
          follows:                                                                    









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