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relief under I.R.C. � 6015(f).
5. Petitioner’s counsel has indicated that peti-
tioner is seeking relief under I.R.C. � 6015(b) and
(f).
* * * * * * *
7. Respondent requests this Court grant his mo-
tion to remand so that he may have an opportunity to
make a determination with respect to petitioner’s claim
for relief from joint and several liability under
I.R.C. � 6015(b) and (f).
On August 10, 2004, the Court denied respondent’s motion to
remand but continued the trial. On August 11, 2004,17 respon-
dent’s counsel referred petitioner’s request for relief under
section 6015 to respondent’s Cincinnati Service Center.
On or about November 11, 2004, petitioner sent to respondent
Form 8857, Request for Innocent Spouse Relief (And Separation of
Liability and Equitable Relief), with respect to her taxable year
1982 (petitioner’s Form 8857). Petitioner attached to peti-
tioner’s Form 8857 Form 12510, Questionnaire for Requesting
Spouse (Form 12510), a preprinted form. The preprinted Form
12510 contained several parts identified as Part 1 through 5.
The instructions to Part 1 of Form 12510 stated: “Complete this
17The parties stipulated that respondent referred peti-
tioner’s request for relief under sec. 6015 to respondent’s
Cincinnati Service Center on Aug. 11, 2003, and not on Aug. 11,
2004. That stipulation is clearly contrary to the facts that we
have found are established by the record, and we shall disregard
it. See Cal-Maine Foods, Inc. v. Commissioner, 93 T.C. 181, 195
(1989). The record establishes, and we have found, that respon-
dent referred petitioner’s request for relief under sec. 6015 to
the Cincinnati Service Center on Aug. 11, 2004.
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