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Given these allegations, petitioner prayed that
this Court may hear the case and determine (i) that
Petitioner is entitled to relief from all joint and
several liability on the joint returns of Petitioner
and her spouse for each of the 1982, 1983, and 1984 tax
years, in the full amount of such liability that was
unpaid as of July 22, 1998, and (ii) that Petitioner is
further entitled to relief from all joint and several
liability for interest, penalties, and other amounts
attributable to such unpaid (as of July 22, 1998)
liability, and (iii) that the Court grant such other
and further relief to which Petitioner may be entitled.
In short, petitioner’s petition took issue with the scope of the
section 6015(b) relief granted to petitioner in the notice of
determination.3
At trial, on January 5, 2004, the parties made a joint
motion for leave to submit case under Tax Court Rule 122, which
the Court granted.
The parties agree that petitioner is entitled to section
6015(b) relief from joint and several liability for the taxable
years 1982, 1983, and 1984. The parties further agree that the
application of section 6015(b) causes petitioner to have a
Federal income tax liability (including interest, penalties, and
other amounts) of zero for those years.
3 We note that the issue of whether petitioner is entitled
to a refund was not specifically raised in the petition but was
subsequently raised and briefed by the parties.
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