Lori Ann Champagne, Petitioner, and Darrin W. Champagne, 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 granted, in part, petitioner’s request for                  
          section 6015 relief with respect to unpaid assessments of $27,714           
          in Federal income tax and a section 6662(a) accuracy-related                
          penalty of $1,162 assessed against petitioner and Darrin W.                 
          Champagne (intervenor) for 2000.  The issue for decision is                 
          whether petitioner is entitled to relief from joint and several             
          liability under section 6015(b), (c), or (f) in excess of the               
          amount determined by respondent.                                            
                                     Background                                       
               The stipulated facts and the exhibits received into evidence           
          are incorporated herein by reference.  At the time the petition             
          in this case was filed, petitioner resided in Magnolia, Texas.              
          At the time the notice of intervention was filed, intervenor                
          resided in Pineland, Texas.                                                 
               Petitioner and intervenor were married in 1993.  The                   
          marriage was dissolved by an agreed final decree of divorce,                
          filed in the district court of Texas, on March 1, 2002.                     
               Petitioner has a bachelor’s degree in elementary education.            
          From January to April of 2000, petitioner was employed by the               
          Magnolia Independent School District as a teacher.  Petitioner              
          stayed home for the remainder of 2000 to care for her newborn               







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