- 2 - her request for relief from joint and several liability pursuant to section 6015. After concessions, the sole issue for decision is whether respondent abused his discretion in denying petitioner’s request for relief from joint and several tax liability pursuant to section 6015 as to 1983. Unless otherwise noted, all section references are to the Internal Revenue Code in effect at all relevant times, and amounts are rounded to the nearest dollar. FINDINGS OF FACT Some facts have been stipulated and are so found. The stipulation of facts, with accompanying exhibits, is incorporated herein by this reference. Petitioner and Mr. Hendricks (collectively, the Hendrickses) were residents of the State of Colorado at all times relevant to this case. The Hendrickses have been married for more than 45 years and have at all times filed joint Federal income tax returns; i.e., Form 1040, U.S. Individual Income Tax Return. Both petitioner and Mr. Hendricks are more than 70 years of age and are retired. Before the Hendrickses married, they agreed to separate their responsibilities, deciding that petitioner would run the household while Mr. Hendricks would be responsible for their finances. Mr. Hendricks worked as a farm manager and a farm and ranch real estate broker, and he invested in real estate. Mr.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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