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Joint tax liability Petitioner’s share
Year before allocation under sec. 6015(c)
1982 $7,474.15 -0-
1983 7,153.00 -0-
1984 6,778.00 -0-
1985 5,029.00 $1,398.06
1986 7,190.00 -0-
1987 1,020.00 -0-
1988 3,907.00 1,953.50
1989 5,712.00 2,856.00
1990 10,957.00 5,478.50
1991 9,535.00 4,767.50
1992 10,521.00 5,260.50
1993 8,330.00 4,165.00
1994 13,827.00 6,913.50
1995 9,306.00 4,653.00
1996 -0- -0-
1997 -0- -0-
106,739.15 37,445.56
The allocation of liability under section 6015(c) was made by
treating petitioner’s and Mr. Owen’s DGE investment as a joint
investment, allocating 50 percent of the partnership items to
petitioner and 50 percent to Mr. Owen in accordance with section
6015(d)(1) and (d)(3)(A), and adjusting the allocation, as
required by section 6015(d)(3)(B), to account for the tax benefit
that petitioner’s share of the partnership items provided to Mr.
Owen on the joint returns. The parties further agreed that
petitioner was not entitled to relief from joint and several
liability under section 6015(b) or (f).
On May 10, 2004, we received and filed petitioner’s motion
for litigation and administrative costs. In her motion,
petitioner asserts that she meets all of the requirements under
section 7430 to recover administrative and litigation costs in
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Last modified: May 25, 2011