Cheryl Kunsman - Page 4

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          were made, Mr. Kunsman had not reached age 59.  The IRA                    
          distributions were reported on Federal income tax returns that              
          were filed with the IRS as joint returns by petitioner and Mr.              
          Kunsman for 1999 and 2000.  No additional tax pursuant to section           
          72(t) was reported.  Petitioner and Mr. Kunsman separated in the            
          fall of 2001 and were divorced in 2002.                                     
               Petitioner first learned that there were proposed                      
          adjustments to the 1999 tax return when respondent offset a                 
          claimed overpayment from her 2001 tax return against a tax                  
          balance due from 1999.1  The amount remaining unpaid for 1999 as            
          of March 2005 was $1,582.58.                                                
               Petitioner timely requested relief from joint and several              
          liability under section 6015 for 1999 and 2000.  Respondent                 
          granted petitioner relief under section 6015(c) for tax year                
          2000.  Respondent issued a Notice of Determination denying relief           
          under section 6015(b), (c), and (f) for 1999.  Petitioner filed a           
          timely petition for review of respondent’s determination.                   
               To support her request for relief from joint and several               
          liability, petitioner asserts:  (1) That the 1999 tax return is             

               1 Apart from respondent's reference to a defaulted statutory           
          notice of deficiency issued to petitioner, the record does not              
          chronicle the deficiency procedures followed by respondent.                 
          Petitioner does not dispute that a deficiency was properly                  
          assessed for 1999.                                                          

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