- 2 - was not entitled to any relief from joint and several liability under section 6015. Petitioner timely filed a petition seeking review of respondent’s determination. The issue for decision is whether respondent’s denial of relief under section 6015(f) was an abuse of discretion. FINDINGS OF FACT Some of the facts have been stipulated. We incorporate the stipulated facts into our findings by this reference. Petitioner resided in Tacoma, Washington, when her petition in this case was filed. Background During the years in issue, petitioner was married to Thomas W. Cowdery (Mr. Cowdery). In May 1997, petitioner and Mr. Cowdery divorced. Petitioner is a high school graduate and has completed some college course work. During the years in issue, petitioner identified her occupation as either child care provider or teacher. Mr. Cowdery changed jobs frequently while married to petitioner, working in construction, drafting, and pyrotechnics. During their marriage, petitioner and Mr. Cowdery maintained a joint bank account, and they discussed their household bills. Mr. Cowdery, however, generally handled their household finances. During the years at issue, petitioner was not aware of any problems with Mr. Cowdery’s handling of their finances, but inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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