Russell Whiting Packer - Page 3

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              Respondent determined a deficiency in petitioner and his                
         former spouse’s Federal income tax of $3,280.10 for 1999.  The               
         issue for decision is whether petitioner is entitled to relief               
         from joint or several liability pursuant to section 6015(b), (c),            
         or (f).                                                                      
              The stipulated facts and the exhibits received into evidence            
         are incorporated herein by reference.  At the time the petition              
         in this case was filed, petitioner resided in Mesa, Arizona.                 
              Petitioner and his former spouse, Leanne Valentine Packer               
         (Ms. Valentine), were married in 1996.  Petitioner and Ms.                   
         Valentine separated in August of 1999.  Petitioner is a college              
         graduate.  During 1999, he was employed by the U.S. Postal                   
         Service.  Ms. Valentine is a high school graduate.  During the               
         relevant periods in 1999, she was employed as a receptionist for             
         an orthodontist.  In 1999, Ms. Valentine received a distribution             
         from her 401(k) account in the amount of $32,802 (distribution).             
              On February 8, 2000, petitioner filed a Petition for                    
         Dissolution of Marriage (Divorce) Without Children in the                    
         Superior Court of Arizona.  On April 15, 2000, petitioner and Ms.            
         Valentine jointly filed a Form 1040, U.S. Individual Income Tax              
         Return, for 1999, which was prepared by a certified public                   
         accountant.  The distribution was reported as income on the                  
         return.  On July 27, 2000, the Superior Court of Arizona entered             

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