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reviewable by any other court, and this opinion should not be
cited as authority.
This case arises from petitioner’s election to seek relief
from joint and several liability for Federal income tax for the
taxable year 1999 under section 6015(b), (c), and (f).
Respondent determined that petitioner was not entitled to such
relief. The issue before this Court is whether petitioner is
entitled to relief under section 6015(b), (c), and (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 the petition was filed, petitioner
resided in Evansville, Wyoming.
During the taxable year at issue, petitioner was married to
Judith Swanson (intervenor). There were no children born of the
marriage. Petitioner and intervenor separated sometime in 1999.
In October 1999, intervenor moved to San Diego, California.
Petitioner and intervenor divorced in 2000.
Petitioner and intervenor’s 1999 Federal income tax return
listed a $3,322 overpayment. Of this amount, respondent offset
$1,659.29 for a liability outstanding from the 1997 taxable year.
Respondent also offset $448.50 for an outstanding liability from
the 1998 taxable year. After these offsets were made, petitioner
received a refund of $1,217.21.
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