Sandrus L. Collier - Page 2

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               The issues remaining for decision are:                                 
               (1) Does the Court have jurisdiction over petitioner’s                 
          request for relief under section 6015(f) for taxable years 1990             
          and 1991?  We hold that we do.                                              
               (2) Did respondent abuse respondent’s discretion in denying            
          petitioner relief under section 6015(f) for taxable years 1988,             
          1989, 1990, and 1991 (years at issue)?2  We hold that respondent            
          did not.                                                                    
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               Sandrus L. Collier (Ms. Collier), resided in Herndon,                  
          Virginia, at the time she filed the petition.                               
               Ms. Collier and Claiborne L. Collier IV (Mr. Collier)                  
          married on April 1, 1978, separated in July 1992, and divorced in           
          January 1997.  During their marriage, Ms. Collier and Mr. Collier           
          had one son, Claiborne Lee Collier V, who at the time of the                
          trial in this case was 20 years old.                                        
               At all relevant times, Ms. Collier knew that Mr. Collier was           
          the father of at least one other child who was living in Califor-           
          nia at all relevant times after 1987.  Ms. Collier also was aware           
          at all relevant times that, at least during and before 1987, Mr.            
          Collier had a support obligation with respect to that child and             

               2On brief, petitioner concedes that she is not entitled to             
          relief under sec. 6015(f) for taxable year 1987.                            

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