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the trial, no part of that assessed deficiency or that assessed
interest had been paid.
Respondent issued an affected items notice to petitioner and
Mr. Korchak with respect to their taxable year 1982. In that
notice, respondent determined that petitioner and Mr. Korchak are
liable for their taxable year 1982 for additions to tax under
sections 6653(a)(1)(A),16 6653(a)(1)(B),16 and 6659 of $7,019.40,
50 percent of the interest due on an assessed deficiency of
$140,388, and $34,322.10, respectively.
In response to the affected items notice, Mr. Korchak filed
a petition with the Court in the case at docket No. 22105-03.
See supra note 3.
In response to the affected items notice, petitioner filed a
petition with the Court. In that petition, petitioner claimed
that she is entitled to relief under section 6015 with respect to
the additions to tax that respondent determined for her taxable
year 1982 as well as interest thereon as provided by law.
On July 30, 2004, respondent filed a motion to remand herein
(respondent’s motion to remand). In that motion, respondent
stated, inter alia:
4. Respondent has not considered petitioner’s
request for relief under I.R.C. � 6015. Specifically,
respondent has not made a determination with respect to
15(...continued)
lished by sec. 6621(c).
16See supra note 2.
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