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both contend that petitioner is not entitled to relief under
either section 6015(b) or (c).
We sustain respondent’s determination that petitioner is not
entitled to relief under section 6015(b), but hold that
petitioner is entitled to partial relief under section 6015(c).
FINDINGS OF FACT
Most of the facts have been stipulated and are so found.
The stipulation of facts and the related exhibits are
incorporated by this reference. Petitioner and intervenor both
resided in California at the time their petition and request for
intervention, respectively, were filed with this Court.
Petitioner was born in 1962 and came to the United States
from Uruguay in June 1984. Before moving to the United States,
petitioner obtained the equivalent of an associate’s degree in
business administration from a community college in Uruguay.
Petitioner is fluent in English.
Intervenor was born in 1955 and is not a college graduate.
Petitioner and intervenor were married on November 30, 1984.
In 1985 and 1986, petitioner and intervenor both worked at the
California State capitol. Petitioner worked as a clerk for an
assemblywoman, and intervenor worked for the California State
senate. Petitioner and intervenor filed joint Federal income tax
returns for 1985 and 1986.
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