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sign that return and certain stipulated exhibits in which she
represented to the IRS that she signed that return. A stipula-
tion is to be treated, to the extent of its terms, as a conclu-
sive admission by the parties to the stipulation, unless other-
wise permitted by the Court or agreed upon by those parties.
Rule 91(e). The Court will not permit a party to a stipulation
to qualify, change, or contradict a stipulation in whole or in
part except that it may do so where justice requires. Justice
does not require the Court to permit petitioner to contradict and
attempt to change the parties’ stipulation that she signed the
1998 return. We shall not rely on petitioner’s testimony to
support her position in this case.
Turning now to our consideration of section 6015(f), as
directed by that section, respondent has prescribed procedures in
Rev. Proc. 2000-15, 2000-1 C.B. 447 (Revenue Procedure 2000-15)9
that are to be used in determining whether it would be inequita-
ble to find the requesting spouse liable for part or all of the
9We note that Rev. Proc. 2003-61, 2003-2 C.B. 296 (Revenue
Procedure 2003-61), superseded Revenue Procedure 2000-15.
Revenue Procedure 2003-61 is effective for requests for relief
under sec. 6015(f) which were filed on or after Nov. 1, 2003, and
for requests for such relief which were pending on, and for which
no preliminary determination letter had been issued as of, that
date. Id. sec. 7. Revenue Procedure 2003-61 is not applicable
in the instant case. That is because (1) petitioner filed
petitioner’s Form 8857 on Jan. 9, 2002, and (2) the IRS issued a
preliminary determination on Sept. 9, 2002 (i.e., the IRS Septem-
ber 9, 2002 preliminary determination) with respect to that form.
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