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declined the opportunity for a new trial or for supplementation
of the record and have expressly consented to reassignment of the
case for opinion and decision. Unless otherwise indicated, all
section references are to the Internal Revenue Code as amended.
The sole issue to be decided is whether petitioner is entitled to
relief under section 6015(f) for 1999.
Background
Some of the facts have been stipulated, and the stipulated
facts are incorporated into our findings by this reference.
Petitioner resided in New Jersey at the time that her petition
was filed. In the midst of personal and financial difficulties,
petitioner and her former spouse, Robert N. Collins (Collins),
separated in mid-1999. The couple formally divorced in May 2000.
On October 26, 2000, petitioner signed a joint Federal income tax
return for 1999, which was not prepared by petitioner and was
later filed by Collins. The return signed by petitioner reported
total tax of $20,850 and a withholding credit of $1,326.
Throughout 1999 and until March 2000, petitioner was
employed as a bookkeeper for Collins’s construction business.
She was aware of all financial information for 1999 regarding the
business. In March 2000, petitioner left her job with Collins’s
business because he wanted to hire his girlfriend. Petitioner
obtained a full-time job shortly thereafter and also received
some spousal and child support incident to the divorce from
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