Webber Douglas Gilmer, Petitioner, and Minnie Payton, Intervenor - Page 4




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          several liability, both in her case and as intervenor in Mr.                
          Gilmer’s case.                                                              
               After the stipulations and Ms. Payton’s concession, the                
          remaining issue before this Court is whether petitioner is                  
          entitled to relief from joint and several liability under section           
          6015(b), (c), or (f).                                                       
                                     Background                                       
               Some of the facts are stipulated.  The stipulated facts and            
          the exhibits received into evidence are incorporated herein by              
          reference.  At the time that his petition was filed, Mr. Gilmer             
          resided in Kansas City, Missouri.                                           
               During the taxable year in issue, Mr. Gilmer was married to            
          Ms. Payton.  There were no children born of the marriage.                   
          Petitioner and Ms. Payton separated sometime in 2001 and divorced           
          in 2004.  Petitioner is employed as a schoolteacher.                        
               Petitioner and Ms. Payton filed a joint 2001 Federal income            
          tax return.  Mr. Gilmer prepared the joint income tax return                
          reporting all sources of income, itemized deductions, and                   
          Schedule C, Profit or Loss From Business, and Schedule E,                   
          Supplemental Income and Loss.  On their joint return, petitioners           
          reported losses on Schedules C and E.  The Schedule C business              
          activity, known as World Works Diversified, encompassed two                 
          separate lines of business: the selling of hats, flags, and other           
          Western-themed novelties, and an educational consulting activity.           







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