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The Forms 1099 for the omitted income were issued solely to
intervenor relating to a pension from his previous employment.
Petitioner has established by a preponderance of the evidence
that the deficiency at issue is entirely allocable to intervenor.
See, e.g., Mora v. Commissioner, supra at 290-291.
The Court holds that respondent erred in denying petitioner
relief under section 6015(c). Accordingly, petitioner is
entitled to relief from joint and several liability under section
6015(c) for 2000. The Court need not address petitioner’s claims
for relief under section 6015(b) and (f).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for petitioner.
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Last modified: May 25, 2011