Joyce A. Siddons, Petitioner, and Richard J. Siddons, Intervenor - Page 3

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               This case arises from petitioner’s election to seek relief             
          from joint and several liability for Federal income tax for the             
          year 1998 under section 6015(b), (c), and (f).  Respondent                  
          determined that petitioner is not entitled to relief.  The issue            
          for decision is whether petitioner is relieved of any liability             
          for tax for 1998 under section 6015(b), (c), or (f).2                       
               Some of the facts were stipulated.  Those facts, with the              
          exhibits annexed thereto, are so found and made part hereof.                
          Petitioner’s legal residence at the time the petition was filed             
          was Jasper, Indiana.                                                        
               During the year at issue, petitioner was married to Richard            
          Siddons (intervenor).3  Petitioner and intervenor were married in           
          1982.  They separated several times for short periods of time               
          during their marriage and were divorced on May 29, 2002.                    
               Petitioner has been employed full time as a cleaning person            
          for a restaurant known as Chicken Place for at least 14 years.              
          In 1998, intervenor owned and operated a small painting business            

               2Petitioner and her former husband also filed their 1997               
          Federal Income tax return timely showing a balance due.  The                
          unpaid liability was fully satisfied by offsetting the parties’             
          1999 and 2000 Federal income tax overpayments and is not an issue           
          in this case.  Although petitioner made reference at trial to               
          being entitled to a “refund” for this collection of unpaid                  
          liability, a request was not included in her petition and is thus           
          not before the Court.                                                       
               3Although intervenor appeared at the calendar call of this             
          case, he was unable to appear at trial due to a medical                     
          condition.  Moreover, intervenor was excused from appearing by              
          the Court.                                                                  

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