Belma Begic, Petitioner, and Zamir Jahic, Intervenor - Page 2

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                                  FINDINGS OF FACT                                    
               On May 31, 1996, petitioner and intervenor were married in             
          Norway.  From January 2001 until August 2002, petitioner attended           
          college in Norway, where she studied electrical engineering.                
          From September 2002 until September 2003, petitioner lived and              
          worked in California.  During 2001 and 2002, Mr. Jahic owned and            
          operated a coffee shop and a night club in Missouri.  In                    
          addition, he maintained the books and records relating to the               
          businesses.  Petitioner did not participate in, and was not                 
          familiar with, the day-to-day operations of the businesses.                 
               Petitioner and Mr. Jahic filed joint Federal income tax                
          returns relating to 2001 and 2002.  Mr. Jahic prepared and signed           
          the returns on behalf of petitioner, but he did not show the                
          returns to, or discuss the items of income with, petitioner.  On            
          May 8, 2004, petitioner and Mr. Jahic’s marriage was dissolved.             
               On December 24, 2004, petitioner timely sent respondent a              
          Form 8857, Request for Innocent Spouse Relief, relating to 2001             
          and 2002.  On March 22, 2005, respondent sent petitioner and Mr.            
          Jahic a notice of deficiency relating to 2001 and 2002.                     
          Respondent determined deficiencies and section 6662(a) accuracy-            
          related penalties relating to 2001 and 2002.  On June 27, 2005,             

          the Internal Revenue Code in effect for the years in issue.                 

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