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toward the tax liability for that year. The remaining issues to
be decided are whether petitioner is eligible for relief from
joint and several liability under section 6015(b) or (c) for
taxable years 1999 and 2001 and whether she is entitled to relief
under section 6015(f) for 1999, 2000, and 2001. Unless otherwise
indicated, all section references are to the Internal Revenue
Code in effect for the years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated into our findings by this reference.
Petitioner resided in the State of Washington at the time she
filed this petition.
Petitioner filed joint Federal income tax returns, all of
which were signed by petitioner, with her former spouse, Daryl F.
Gonce (Mr. Gonce), for the years in issue. Petitioner and
Mr. Gonce reported overpayments on their 1998 and 1999 Federal
tax returns of $2,357 and $2,083, respectively. Petitioner and
Mr. Gonce reported underpayments on their 2000 and 2001 returns
of $1,188 and $2,528, respectively.
Petitioner and Mr. Gonce were married in 1980, separated in
2002, and divorced in 2004. Petitioner and Mr. Gonce have three
children, the youngest of whom was approximately 20 years old at
the time of trial.
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