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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
The issue for decision is whether petitioner under section
6015(g)(2) is barred from obtaining relief from joint liability
for the tax deficiencies which were sustained in Huynh v.
Commissioner, supra.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner resided in
San Diego, California.
From 1979 through 1997, petitioner worked for the County of
San Diego Department of Social Services as an eligibility
technician, reviewing the eligibility of those seeking social
service benefits. Petitioner speaks and reads English.
In May of 1996, petitioner’s husband (Hong), who apparently
possesses numerous college and graduate degrees, including a law
degree, was laid off from his job. Hong had purchased insurance
coverage which provided, among other things, that in the event
Hong became unemployed the insurers would make payments on some
portion of the outstanding balance due on his 11 credit cards.
When Hong became unemployed, the insurers began making
monthly payments on his credit cards. At the end of 1996, Hong’s
credit cards reflected a total outstanding balance of $91,333.
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