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other court, and this opinion shall not be treated as precedent
for any other case.
Respondent determined a deficiency in petitioners’ Federal
income tax for 2004 of $1,684. As petitioners have conceded the
deficiency, the sole issue remaining for decision is whether
petitioners are each entitled to relief from joint and several
liability from the deficiency under section 6015.
Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulations of
facts at trial and accompanying exhibits.
At the time the petition was filed, Floyd William Munsinger
(Mr. Munsinger) and Audreanne Elise Lewallen (Ms. Lewallen),
jointly referred to herein as petitioners, resided in Wyoming.
For the taxable year 2004, petitioners were married and
filed a joint Federal income tax return. The return was prepared
by H&R Block based on information and documents furnished by
petitioners.
Petitioners erroneously omitted $8,203 of wage income from
their 2004 return, $2,886 of which was attributable to Ms.
Lewallen and $5,317 of which was attributable to Mr. Munsinger.
The omitted wage income represented one-third of petitioners’
total income for the year. Ms. Lewallen had actual knowledge of
Mr. Munsinger’s various employments, specifically including his
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