This summary provides the essential information from the document in 3 sentences:
This document is a summary opinion from the United States Tax Court regarding whether William Pearce is entitled to relief from joint and several tax liability for tax year 2004. The tax return for 2004 claimed a deduction for state and local income taxes that was not allowed, resulting in an underpayment. Pearce is not eligible for relief under section 6015(b), (c), or (f) because the improper deduction was attributable to his income and he signed declarations stating he reviewed the return.
Newtown Loses By Default Judgment- NECA -vs- KaaihueAngela Kaaihue
Newtown Loses By Default Judgment- NECA -vs- Kaaihue, a five year litigation and court battle. When NECA board of directors, and community are jealous for driving right by a property that could have been purchased, but was inherited by Angela Kaaihue, who has turned the property she inherited into a Hawaiian Gold Mine.
Hawaii Appellant Court Supreme Court judge castegnetti, judge jeffrey crabtree, judge karen t. nakasone, judge katherine g. leonard, judge keith hiraoka, judge lisa m. ginoza, judge sonja mccullen, judge clyde j. wadsworth, judge karen holma, judge gary W.B. chang
State's Objection to Motion For Sanctions Against Tara Heater, Martha Ann Hor...Rich Bergeron
Answering a pile of documented accusations with a couple pages of complete BS, Attorney Tara Heater still hasn't provided any affidavits to back up her lies. This is her objection to my latest motion, which basically says she'd like to rely on her objection to the last motion for sanctions. Total laziness and obviously now a matter of being afraid to dig herself deeper.
State's Objection to Motion to Dismiss (Filed by Deputy Grafton County Attorn...Rich Bergeron
After two straight motions with no response, Tara Heater finally has something to say and doesn't want the case thrown out. Judge O'Neill will no doubt give her whatever she wants, no matter how poorly she is prepared for trial. See more at www.nhdrugtaskforce.com
BIA Remands of Immigration Judge James Nugent from 01/01/2014 to 05/26/2016Bryan Johnson
EOIR FOIA ID # 2016-23184. Also, see acknowledgment letter at following link: http://www.slideshare.net/abogadobryan/eoir-acknowledgment-letter-for-201623284
BIA Remands of Immigration Judge Theresa Holmes-Simmons from 01/01/2014 to 05...Bryan Johnson
EOIR FOIA ID # 2016-23184. Also, see acknowledgment letter at following link: http://www.slideshare.net/abogadobryan/eoir-acknowledgment-letter-for-201623284
Defendant's Reply to State's Objection to Motion to Dismiss (Speedy Trial)Rich Bergeron
Here I take the prosecutor from Grafton County to task for all her mistakes and lack of proper legal analysis. Judge O'Neill will still rule in her favor, no matter how lax in her duties she is. I do go overboard and keep insisting the state had no motion pending. There was actually a motion to amend before the court, so I screwed up myself there, but not nearly as badly as Deputy Grafton County Attorney Tara Heater did.
Newtown Loses By Default Judgment- NECA -vs- KaaihueAngela Kaaihue
Newtown Loses By Default Judgment- NECA -vs- Kaaihue, a five year litigation and court battle. When NECA board of directors, and community are jealous for driving right by a property that could have been purchased, but was inherited by Angela Kaaihue, who has turned the property she inherited into a Hawaiian Gold Mine.
Hawaii Appellant Court Supreme Court judge castegnetti, judge jeffrey crabtree, judge karen t. nakasone, judge katherine g. leonard, judge keith hiraoka, judge lisa m. ginoza, judge sonja mccullen, judge clyde j. wadsworth, judge karen holma, judge gary W.B. chang
State's Objection to Motion For Sanctions Against Tara Heater, Martha Ann Hor...Rich Bergeron
Answering a pile of documented accusations with a couple pages of complete BS, Attorney Tara Heater still hasn't provided any affidavits to back up her lies. This is her objection to my latest motion, which basically says she'd like to rely on her objection to the last motion for sanctions. Total laziness and obviously now a matter of being afraid to dig herself deeper.
State's Objection to Motion to Dismiss (Filed by Deputy Grafton County Attorn...Rich Bergeron
After two straight motions with no response, Tara Heater finally has something to say and doesn't want the case thrown out. Judge O'Neill will no doubt give her whatever she wants, no matter how poorly she is prepared for trial. See more at www.nhdrugtaskforce.com
BIA Remands of Immigration Judge James Nugent from 01/01/2014 to 05/26/2016Bryan Johnson
EOIR FOIA ID # 2016-23184. Also, see acknowledgment letter at following link: http://www.slideshare.net/abogadobryan/eoir-acknowledgment-letter-for-201623284
BIA Remands of Immigration Judge Theresa Holmes-Simmons from 01/01/2014 to 05...Bryan Johnson
EOIR FOIA ID # 2016-23184. Also, see acknowledgment letter at following link: http://www.slideshare.net/abogadobryan/eoir-acknowledgment-letter-for-201623284
Defendant's Reply to State's Objection to Motion to Dismiss (Speedy Trial)Rich Bergeron
Here I take the prosecutor from Grafton County to task for all her mistakes and lack of proper legal analysis. Judge O'Neill will still rule in her favor, no matter how lax in her duties she is. I do go overboard and keep insisting the state had no motion pending. There was actually a motion to amend before the court, so I screwed up myself there, but not nearly as badly as Deputy Grafton County Attorney Tara Heater did.
The debtor must provide the chapter 13 case trustee with a copy of the tax return or transcripts for the most recent tax year as well as tax returns filed during the case.
FLSA Litigation - Federal Court - MDFL Tampa - Fee Entitlement & MootnessPollard PLLC
Lawyers in FLSA cases and particularly on the defense side should view this as a cautionary tale: Tendering a check for the wages at issue does not moot the plaintiff's claim. FLSA claims are live until there is a judgment or a settlement approved by the court. And plaintiffs DO get their fees for litigating over the issue of attorneys' fees.
Simply put: A legitimate FLSA case, a skilled attorney on the plaintiff side, and defense counsel who do not understand the applicable legal framework make for disastrous results.
Relief from Joint & Several Liability: Innocent Spouse Reliefgppcpa
Many married taxpayers choose to file a joint tax return because of certain benefits this filing status allows. In filing jointly, both taxpayers are jointly and severally liable for the tax and any additions to tax, interest, or penalties that arise as a result of the joint return even if they later divorce.Joint and several liability means that each taxpayer is legally responsible for the entire liability. Thus, both spouses are generally held responsible for all the tax due even if one spouse earned all the income or claimed improper deductions or credits. This is also true even if a divorce decree states that a former spouse will be responsible for any amounts due on previously filed joint returns. In some cases, however, a spouse can get relief from joint and several liability.
Order denying Abbott Labs Motion for Summary Judgment and finding in favor of...Mark Briggs
Ray Dieppa Raymond Dieppa Ray Dieppa Raymond Dieppa personal injury employment discrimination abbot labs settlement verdict attorney raymond dieppa attorney lawyer attorney federal diversity
at will employment breach of employment
Sample motion to vacate California divorce judgment for fraud and perjuryLegalDocsPro
This sample motion to vacate a dissolution (divorce) judgment in California on the grounds of fraud and perjury is filed pursuant to the provisions of California Family Code sections 2122(a) and (b). This sample can also be used to vacate a legal separation or nullity judgment in California as well. The sample on which this preview is based is 10 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority and a sample declaration.
State of ICS and IoT Cyber Threat Landscape Report 2024 previewPrayukth K V
The IoT and OT threat landscape report has been prepared by the Threat Research Team at Sectrio using data from Sectrio, cyber threat intelligence farming facilities spread across over 85 cities around the world. In addition, Sectrio also runs AI-based advanced threat and payload engagement facilities that serve as sinks to attract and engage sophisticated threat actors, and newer malware including new variants and latent threats that are at an earlier stage of development.
The latest edition of the OT/ICS and IoT security Threat Landscape Report 2024 also covers:
State of global ICS asset and network exposure
Sectoral targets and attacks as well as the cost of ransom
Global APT activity, AI usage, actor and tactic profiles, and implications
Rise in volumes of AI-powered cyberattacks
Major cyber events in 2024
Malware and malicious payload trends
Cyberattack types and targets
Vulnerability exploit attempts on CVEs
Attacks on counties – USA
Expansion of bot farms – how, where, and why
In-depth analysis of the cyber threat landscape across North America, South America, Europe, APAC, and the Middle East
Why are attacks on smart factories rising?
Cyber risk predictions
Axis of attacks – Europe
Systemic attacks in the Middle East
Download the full report from here:
https://sectrio.com/resources/ot-threat-landscape-reports/sectrio-releases-ot-ics-and-iot-security-threat-landscape-report-2024/
Kubernetes & AI - Beauty and the Beast !?! @KCD Istanbul 2024Tobias Schneck
As AI technology is pushing into IT I was wondering myself, as an “infrastructure container kubernetes guy”, how get this fancy AI technology get managed from an infrastructure operational view? Is it possible to apply our lovely cloud native principals as well? What benefit’s both technologies could bring to each other?
Let me take this questions and provide you a short journey through existing deployment models and use cases for AI software. On practical examples, we discuss what cloud/on-premise strategy we may need for applying it to our own infrastructure to get it to work from an enterprise perspective. I want to give an overview about infrastructure requirements and technologies, what could be beneficial or limiting your AI use cases in an enterprise environment. An interactive Demo will give you some insides, what approaches I got already working for real.
GraphRAG is All You need? LLM & Knowledge GraphGuy Korland
Guy Korland, CEO and Co-founder of FalkorDB, will review two articles on the integration of language models with knowledge graphs.
1. Unifying Large Language Models and Knowledge Graphs: A Roadmap.
https://arxiv.org/abs/2306.08302
2. Microsoft Research's GraphRAG paper and a review paper on various uses of knowledge graphs:
https://www.microsoft.com/en-us/research/blog/graphrag-unlocking-llm-discovery-on-narrative-private-data/
Transcript: Selling digital books in 2024: Insights from industry leaders - T...BookNet Canada
The publishing industry has been selling digital audiobooks and ebooks for over a decade and has found its groove. What’s changed? What has stayed the same? Where do we go from here? Join a group of leading sales peers from across the industry for a conversation about the lessons learned since the popularization of digital books, best practices, digital book supply chain management, and more.
Link to video recording: https://bnctechforum.ca/sessions/selling-digital-books-in-2024-insights-from-industry-leaders/
Presented by BookNet Canada on May 28, 2024, with support from the Department of Canadian Heritage.
UiPath Test Automation using UiPath Test Suite series, part 3DianaGray10
Welcome to UiPath Test Automation using UiPath Test Suite series part 3. In this session, we will cover desktop automation along with UI automation.
Topics covered:
UI automation Introduction,
UI automation Sample
Desktop automation flow
Pradeep Chinnala, Senior Consultant Automation Developer @WonderBotz and UiPath MVP
Deepak Rai, Automation Practice Lead, Boundaryless Group and UiPath MVP
Neuro-symbolic is not enough, we need neuro-*semantic*Frank van Harmelen
Neuro-symbolic (NeSy) AI is on the rise. However, simply machine learning on just any symbolic structure is not sufficient to really harvest the gains of NeSy. These will only be gained when the symbolic structures have an actual semantics. I give an operational definition of semantics as “predictable inference”.
All of this illustrated with link prediction over knowledge graphs, but the argument is general.
Dev Dives: Train smarter, not harder – active learning and UiPath LLMs for do...UiPathCommunity
💥 Speed, accuracy, and scaling – discover the superpowers of GenAI in action with UiPath Document Understanding and Communications Mining™:
See how to accelerate model training and optimize model performance with active learning
Learn about the latest enhancements to out-of-the-box document processing – with little to no training required
Get an exclusive demo of the new family of UiPath LLMs – GenAI models specialized for processing different types of documents and messages
This is a hands-on session specifically designed for automation developers and AI enthusiasts seeking to enhance their knowledge in leveraging the latest intelligent document processing capabilities offered by UiPath.
Speakers:
👨🏫 Andras Palfi, Senior Product Manager, UiPath
👩🏫 Lenka Dulovicova, Product Program Manager, UiPath
Builder.ai Founder Sachin Dev Duggal's Strategic Approach to Create an Innova...Ramesh Iyer
In today's fast-changing business world, Companies that adapt and embrace new ideas often need help to keep up with the competition. However, fostering a culture of innovation takes much work. It takes vision, leadership and willingness to take risks in the right proportion. Sachin Dev Duggal, co-founder of Builder.ai, has perfected the art of this balance, creating a company culture where creativity and growth are nurtured at each stage.
Smart TV Buyer Insights Survey 2024 by 91mobiles.pdf91mobiles
91mobiles recently conducted a Smart TV Buyer Insights Survey in which we asked over 3,000 respondents about the TV they own, aspects they look at on a new TV, and their TV buying preferences.
LF Energy Webinar: Electrical Grid Modelling and Simulation Through PowSyBl -...DanBrown980551
Do you want to learn how to model and simulate an electrical network from scratch in under an hour?
Then welcome to this PowSyBl workshop, hosted by Rte, the French Transmission System Operator (TSO)!
During the webinar, you will discover the PowSyBl ecosystem as well as handle and study an electrical network through an interactive Python notebook.
PowSyBl is an open source project hosted by LF Energy, which offers a comprehensive set of features for electrical grid modelling and simulation. Among other advanced features, PowSyBl provides:
- A fully editable and extendable library for grid component modelling;
- Visualization tools to display your network;
- Grid simulation tools, such as power flows, security analyses (with or without remedial actions) and sensitivity analyses;
The framework is mostly written in Java, with a Python binding so that Python developers can access PowSyBl functionalities as well.
What you will learn during the webinar:
- For beginners: discover PowSyBl's functionalities through a quick general presentation and the notebook, without needing any expert coding skills;
- For advanced developers: master the skills to efficiently apply PowSyBl functionalities to your real-world scenarios.
Generating a custom Ruby SDK for your web service or Rails API using Smithyg2nightmarescribd
Have you ever wanted a Ruby client API to communicate with your web service? Smithy is a protocol-agnostic language for defining services and SDKs. Smithy Ruby is an implementation of Smithy that generates a Ruby SDK using a Smithy model. In this talk, we will explore Smithy and Smithy Ruby to learn how to generate custom feature-rich SDKs that can communicate with any web service, such as a Rails JSON API.
Software Delivery At the Speed of AI: Inflectra Invests In AI-Powered QualityInflectra
In this insightful webinar, Inflectra explores how artificial intelligence (AI) is transforming software development and testing. Discover how AI-powered tools are revolutionizing every stage of the software development lifecycle (SDLC), from design and prototyping to testing, deployment, and monitoring.
Learn about:
• The Future of Testing: How AI is shifting testing towards verification, analysis, and higher-level skills, while reducing repetitive tasks.
• Test Automation: How AI-powered test case generation, optimization, and self-healing tests are making testing more efficient and effective.
• Visual Testing: Explore the emerging capabilities of AI in visual testing and how it's set to revolutionize UI verification.
• Inflectra's AI Solutions: See demonstrations of Inflectra's cutting-edge AI tools like the ChatGPT plugin and Azure Open AI platform, designed to streamline your testing process.
Whether you're a developer, tester, or QA professional, this webinar will give you valuable insights into how AI is shaping the future of software delivery.
Software Delivery At the Speed of AI: Inflectra Invests In AI-Powered Quality
Pearce v. commissioner
1. T.C. Summary Opinion 2011-98
UNITED STATES TAX COURT
WILLIAM GERARD PEARCE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6053-09S. Filed July 26, 2011.
William Gerard Pearce, pro se.
John R. Bampfield, for respondent.
HAINES, Judge: This case was heard pursuant to the
provisions of section 7463 of the Internal Revenue Code in effect
when the petition was filed.1 Pursuant to section 7463(b), the
decision to be entered is not reviewable by any other court, and
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, as amended, and Rule
references are to the Tax Court Rules of Practice and Procedure.
Amounts are rounded to the nearest dollar.
2. - 2 -
this opinion shall not be treated as precedent for any other
case.
This proceeding was commenced under section 6015 for review
of respondent’s determination that petitioner is not entitled to
relief from joint and several liability with respect to an
understatement of Federal income tax reported on a joint Federal
income tax return filed for 2004.
Background
The parties’ stipulation of facts and supplemental
stipulation of facts and the attached exhibits are incorporated
herein by this reference. Petitioner resided in Tennessee when
he filed his petition.
On August 23, 2006, respondent received petitioner and his
former spouse’s 2004 joint income tax return (the joint return).
On Schedule A, Itemized Deductions, petitioner and his former
spouse claimed a deduction of $27,200 for State and local income
taxes paid. As a result, petitioner and his former spouse
claimed a refund of $4,379. Petitioner’s reported wages in 2004
were $27,200, the exact amount also reported as State and local
income taxes paid. Petitioner’s former spouse prepared the joint
return. Petitioner did not review the joint return, and neither
petitioner nor his former spouse signed it.
On September 15, 2006, respondent sent petitioner and his
former spouse a letter informing them that the joint return was
3. - 3 -
not signed and a declaration requiring their signatures was
needed to remedy their initial failure to sign. The declaration
stated:
Under penalties of perjury, I declare that I have examined
the return (including any accompanying schedules and
statements) referred to in this letter and, to the best of
my knowledge and belief, it is true, correct, and complete.
Petitioner and his former spouse signed the declaration, but
petitioner again did not examine the joint return before
signing. Petitioner was aware at the time he signed the
declaration that Tennessee did not have a State income tax.
Petitioner unsuccessfully attempted to contact the Internal
Revenue Service (IRS) to ask when a refund check for 2004 would
arrive. On October 27, 2006, respondent issued a refund check
for $4,379 to petitioner and his former spouse. Despite
petitioner’s former spouse’s request that the refund check be
sent to her mother’s home, it was sent to the home petitioner
and his former spouse shared in 2006. Petitioner did not
receive the refund check. However, on November 10, 2006,
petitioner’s former spouse deposited the refund check in their
joint bank account. Petitioner’s former spouse used the
proceeds of the refund check for her benefit in small increments
throughout November and December 2006. Petitioner believed the
joint bank account was an “empty account” during that time
because petitioner and his former spouse were working through
mediation in their divorce proceedings. On July 16, 2008, the
4. - 4 -
Circuit Court of Tennessee for the 30th Judicial District of
Memphis issued a final decree of divorce between petitioner and
his former spouse.
On December 17, 2007, respondent issued Form 4549, Income
Tax Examination Changes, disallowing the $27,200 State and local
income tax deduction. Respondent further issued a notice of
deficiency on February 11, 2008, determining a deficiency in
income tax against petitioner and his former spouse of $2,670.
On February 27, 2008, petitioner signed Form 8857, Request for
Innocent Spouse Relief, requesting relief from the deficiency.
On December 11, 2008, respondent issued a final Appeals
determination letter denying petitioner’s request for relief
from joint and several liability. Petitioner filed a timely
petition with this Court challenging respondent’s determination.
Discussion
Generally, when a husband and wife file a joint Federal
income tax return, they are jointly and severally liable for the
full amount of the tax. Sec. 6013(d)(3); Butler v.
Commissioner, 114 T.C. 276, 282 (2000). However, a spouse may
qualify for relief from joint and several liability under
section 6015(b), (c), or (f) if various requirements are met.
Petitioner contends he qualifies for full relief from joint
liability under section 6015(b) and (c), and if not, that he is
entitled to equitable relief under section 6015(f).
5. - 5 -
A. Relief From Joint and Several Liability Under Section
6015(b)
Section 6015(b)(1) authorizes the Commissioner to grant
relief from joint and several liability for tax (including
interest, penalties, and other amounts) if the taxpayer
requesting relief satisfies each of the following five
requirements of subparagraphs (A) through (E):
(A) a joint return has been made for a taxable
year;
(B) on such return there is an understatement of
tax attributable to erroneous items of one individual
filing the joint return;
(C) the other individual filing the joint return
establishes that in signing the return he or she did
not know, and had no reason to know, that there was
such understatement;
(D) taking into account all the facts and
circumstances, it is inequitable to hold the other
individual liable for the deficiency in tax for such
taxable year attributable to such understatement; and
(E) the other individual elects (in such form as
the Secretary may prescribe) the benefits of this
subsection not later than the date which is 2 years
after the date the Secretary has begun collection
activities with respect to the individual making the
election * * *
The requesting spouse bears the burden of proving that he
satisfies each of these five requirements. See Rule 142(a);
Jonson v. Commissioner, 118 T.C. 106, 113 (2002), affd. 353 F.3d
1181 (10th Cir. 2003). If the requesting spouse fails to meet
any one of the five requirements, he fails to qualify for
relief. Alt v. Commissioner, 119 T.C. 306, 313 (2002), affd.
6. - 6 -
101 Fed. Appx. 34 (6th Cir. 2004). Respondent does not dispute
that petitioner satisfies two requirements of section
6015(b)(1); namely, those regarding the filing of a joint return
and making a timely election under section 6015(b)(1)(A) and
(E), respectively. Thus, we must consider whether petitioner
satisfies the remaining three requirements of section
6015(b)(1).
The first requirement, in section 6015(b)(1)(B), is that an
understatement of tax be attributable to erroneous items of the
other person filing the joint return. The joint return claimed
a deduction for $27,200 of State and local income tax that was
not due or paid. This deduction was for the exact amount
petitioner reported as wages in 2004. Accordingly, the
deduction is attributable to him. Further, petitioner signed
the declaration stating under penalties of perjury that he had
examined the joint return and to the best of his knowledge and
belief it was true, correct, and complete. Because each of the
five requirements of the statute must be satisfied for relief,
petitioner is not eligible for relief from joint and several
liability under section 6015(b)(1) and we need not consider the
other requirements.
B. Relief From Joint and Several Liability Under Section
6015(c)
Petitioner further claims eligibility for relief under
section 6015(c). Under section 6015(c), if the requesting
7. - 7 -
spouse is no longer married to, or is legally separated from,
the spouse with whom he filed the joint return, the requesting
spouse may elect to limit his liability to the deficiency
properly allocable to him. As discussed above, the $27,200
State and local income tax deduction is allocable to petitioner.
Accordingly, petitioner is not eligible for relief from joint
and several liability under section 6015(c).
C. Relief From Joint and Several Liability Under Section
6015(f)
Relief may be granted from joint and several liability
under section 6015(f) if “(1) taking into account all the facts
and circumstances, it is inequitable to hold the individual
liable for any unpaid tax or any deficiency (or any portion of
either); and (2) relief is not available to such individual
under subsection (b) or (c)”. This Court has jurisdiction to
determine whether a taxpayer is entitled to equitable relief
under section 6015(f). Sec. 6015(e)(1)(A); see also Farmer v.
Commissioner, T.C. Memo. 2007-74. Our determination is made in
a trial de novo. Porter v. Commissioner, 130 T.C. 115, 117
(2008).
The Commissioner prescribed procedures in Rev. Proc. 2003-
61, 2003-2 C.B. 296, that IRS personnel must use to determine
whether a requesting spouse qualifies for relief under section
6015(f). According to Rev. Proc. 2003-61, sec. 4.01, 2003-2
C.B. at 297-298, a requesting spouse must satisfy seven
8. - 8 -
conditions (threshold conditions) before the Commissioner will
consider a request for relief under section 6015(f). The
threshold conditions of this section are stated in the
conjunctive, and each condition must be satisfied for the spouse
to be eligible for relief under section 6015(f). Id. The
parties do not dispute that the first six threshold conditions
have been satisfied.2
The final threshold condition, as set forth in Rev. Proc.
2003-61, sec. 4.01(7), 2003-2 C.B. at 297-298, is that the
income tax liability from which the requesting spouse seeks
relief must be attributable to an item of the nonrequesting
spouse, unless one of four enumerated exceptions applies.3 As
discussed above, the deduction of $27,200 for State and local
income taxes is attributable to petitioner. Petitioner does not
qualify for any of the enumerated exceptions. Accordingly,
2
The first six threshold conditions require that: (1) The
requesting spouse file a joint return for the year at issue; (2)
relief not be available under sec. 6015(b) or (c); (3) the
requesting spouse apply for relief no later than 2 years after
the date of the IRS’ first collection activity after July 22,
1998, with respect to the requesting spouse; (4) no assets be
transferred between the spouses as part of a fraudulent scheme;
(5) the nonrequesting spouse not transfer disqualifying assets to
the requesting spouse; and (6) the requesting spouse not file or
fail to file the return with fraudulent intent. Rev. Proc. 2003-
61, sec. 4.01, 2003-2 C.B. 296, 297.
3
The four exceptions are: (1) Attribution due solely to the
operation of community property law; (2) nominal ownership; (3)
misappropriation of funds; and (4) abuse not amounting to duress.
Id. sec. 4.01(7), 2003-2 C.B. at 297-298.
9. - 9 -
petitioner has failed to meet the threshold conditions for
consideration for relief from joint and several liability
pursuant to section 6015(f).
In reaching these holdings, the Court has considered all
arguments made and, to the extent not mentioned, concludes that
they are moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.