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section 6015(f) only with respect to 50 percent of petitioner’s
and John’s $17,516 underpayment and under section 6015(c) only
with respect to 50 percent of petitioner and John’s $6,452
deficiency, as follows, subject to any applicable limitations
under Rev. Proc. 2003-61, sec. 4.04(2) and sec. 6015(g)(3):
Nature of Amount of Appeals Office Relief
Liability Liability Amount Basis for
Underpayment $17,516 $8,792 Sec. 6015(f)
Deficiency $6,452 $3,226 Sec. 6015(c)
Respondent’s Appeals Office’s determination (to grant
petitioner relief from joint liability only as to 50 percent of
the $17,516 underpayment and as to 50 percent of the $6,452
deficiency) was based primarily on respondent’s analysis that the
other 50 percent of the underpayment and the other 50 percent of
the deficiency were attributable to what respondent regarded as
petitioner’s 50-percent ownership interest in MGI.
With regard to the portion of the underpayment from which
respondent determined that petitioner should be granted relief
under section 6015(f), respondent’s Appeals Office determined
that the factors set forth in Rev. Proc. 2003-61, sec. 4.03,
2003-2 C.B. at 298, supported such relief.
With regard to the portion of the deficiency from which
respondent determined that petitioner should be granted relief
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