Webber Douglas Gilmer, Petitioner, and Minnie Payton, Intervenor - Page 3




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          filed.  Pursuant to section 7463(b), the decisions to be entered            
          are not reviewable by any other court, and this opinion shall not           
          be treated as precedent for any other case.  Unless otherwise               
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for the year in issue, and all Rule                  
          references are to the Tax Court Rules of Practice and Procedure.            
               In a joint notice of deficiency mailed to petitioners,                 
          respondent determined a deficiency in petitioners’ 2001 Federal             
          income tax of $11,747 and an accuracy-related penalty of                    
          $2,349.40 pursuant to section 6662(a).                                      
               Each petitioner filed a separate petition.  Webber Douglas             
          Gilmer’s (petitioner) petition seeks a redetermination of the               
          deficiency and the accuracy-related penalty, and his amended                
          petition seeks relief from joint and several liability on their             
          joint return for 2001 pursuant to section 6015.  Minnie Ruth                
          Payton’s (Ms. Payton) petition also seeks relief from joint and             
          several liability on their joint return for 2001.  Each                     
          petitioner filed a notice of intervention in the other’s case.              
               When these cases were called for trial, the parties in each            
          filed a stipulation of settled issues.  In the stipulation,                 
          petitioners stipulated a deficiency for 2001 in the amount of               
          $5,722, and an accuracy-related penalty of $1,144.  Further, Ms.            
          Payton, at trial, conceded her claim for relief from joint and              








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