Francine Edwards - Page 3

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          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              
               The issues for decision are whether:  (1) The Court has                
          jurisdiction in this proceeding to review the grant by the                  
          Internal Revenue Service (IRS) of innocent spouse relief to                 
          petitioner’s former spouse; and (2) petitioner’s liability should           
          be limited to 50 percent of the deficiency.                                 
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the exhibits received into evidence            
          are incorporated herein by reference.  At the time the petition             
          was filed, petitioner resided in Fall River, Massachusetts.                 
               Petitioner and Jacob Edwards (former spouse) filed a joint             
          Federal income tax return for 2001.  Petitioner and her former              
          spouse reported $115,297 on line 22, total income.  Respondent’s            
          third party payer reports, however, showed that petitioner                  
          received and failed to report the following items of income:                
          (1) $440 as compensation for services reported on a Form W-2,               
          Wage and Tax Statement; (2) $3,339 in unemployment compensation             
          reported on a Form 1099-G, Certain Government Payments; (3) $12             
          in interest reported on a Form 1099-INT, Interest Income; and               
          (4) $6,522 in gross distributions from an individual retirement             
          account reported on a Form 1099-R, Distributions From Pensions,             
          Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance              

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