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the payment made from her separate property unless sec.
6511, I.R.C., applies.
Held: P is not entitled to a refund of amounts
from community property used to pay H’s understate-
ments.
Clayton J. Vreeland, for petitioner.
Patrick W. Lucas, for respondent.
OPINION
GOEKE, Judge: Respondent determined that petitioner is
entitled to relief under section 6015(b).1 The issue for
decision is the amount of refund, if any, petitioner is entitled
to under section 6015(g).
Background
The parties submitted this case fully stipulated under Rule
122. The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
On July 26, 2002, respondent sent petitioner a Notice of
Determination Concerning Your Request for Relief from Joint and
Several Liability Under Section 6015 (notice of determination).
The notice of determination indicates that petitioner is entitled
to relief under section 6015(b) of $160,912 for taxable years
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
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