Barbara A. Owen - Page 10

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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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