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The decision to be entered is not reviewable by any other court,
and this opinion should not be cited as authority.
Respondent determined a deficiency in petitioner’s Federal
income taxes for 2001 of $2,210. After a timely petition was
filed, respondent conceded that petitioner is entitled to relief
from joint and several liability under section 6015(c).1 Wendy
Houdeshell (intervenor) filed a Notice of Intervention. The
Court must decide whether respondent erred in granting relief to
petitioner under section 6015(c).
Background
Some of the facts are stipulated. The stipulated facts and
the exhibits received into evidence are incorporated herein by
reference. At the time the petition was filed, and at the time
notice of intervention was filed, petitioner and intervenor
resided in Dearborn, Michigan.
During 2001, petitioner was married to intervenor. They did
not reside together during the year. Intervenor resided in the
marital home from January through June 2001. When she moved out,
petitioner moved back in and resided there for the remainder of
the year. They divorced on December 9, 2002.
1Respondent also concedes that petitioner’s deficiency
before the application of sec. 6015(c) is $1,629.
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