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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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Last modified: May 25, 2011