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called Hoosier Painting that specialized in painting interiors
and exteriors of residential homes.
Petitioner and intervenor filed their 1998 joint Federal
income tax return timely. The return reported wages from
petitioner’s employment of $14,456 and a credit for withheld
Federal income tax of $1,372. The return also included a
Schedule C, Profit or Loss From Business, for intervenor’s
painting business. That activity reflected a net profit of
$33,740. The tax shown on the return was $7,563, which included
$4,767 of self-employment tax from intervenor’s trade or business
activity.
The return was prepared and filed by a certified public
accountant and was signed by both parties. Respondent agrees
that the unpaid liability is solely attributable to intervenor’s
income.
Petitioner filed Form 8857, Request for Innocent Spouse
Relief, with the Internal Revenue Service (IRS) on or about
November 4, 2002. The IRS subsequently denied relief, and
petitioner filed a timely petition in this Court. Petitioner’s
sole position is that she is entitled to relief from joint
liability under section 6015. Respondent, pursuant to Rule 325
and King v. Commissioner, 115 T.C. 118 (2000), served notice of
this proceeding on intervenor, who filed a Notice of Intervention
on April 19, 2004. However, in his intervention, intervenor did
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