Teresa J. Fox - Page 4

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          with the Internal Revenue Service in the fall of 2004 to pay $83            
          per month for those years, and she has abided by that agreement.            
          C.   Petitioner’s Finances                                                  
               Petitioner’s expenses approximated her income in 2004 and              
          2005.  At the time of trial, petitioner’s 19-year-old son from a            
          prior relationship lived with her and attended college.                     
          Petitioner gives her son significant financial support.                     
          D.   Petitioner’s Application for Relief From Joint Tax Liability           
               On September 30, 2004, petitioner sent to respondent a Form            
          8857, Request for Innocent Spouse Relief, which respondent                  
          denied.2  Petitioner concedes the underlying tax liability, but             
          contends that she is entitled to relief from joint liability                
          under section 6015(f).                                                      
          A.   Petitioner’s Contentions and Background                                
               Petitioner contends that she qualifies under section 6015(f)           
          for relief from joint liability for tax.  This Court has                    
          jurisdiction to decide whether a taxpayer is entitled to relief             
          from joint liability under section 6015(f).  Sec. 6015(e); Ewing            
          v. Commissioner, 118 T.C. 494, 497-507 (2002), on appeal (9th               
          Cir., June 16, 2004), cross-appeal (9th Cir., July 19, 2004).               

               2  By leave of another Division of this Court, petitioner              
          raised her claim under sec. 6015 as an affirmative defense in the           
          deficiency proceedings.                                                     

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