Luis A. Vasquez, Petitioner, and Wendy Houdeshell, n.k.a. Wendy Gray, Intervenor - Page 3

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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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