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whether respondent abused his discretion in denying petitioner
relief from joint and several liability under section 6015(f).
Unless otherwise indicated, all section references are to
the Internal Revenue Code.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. At the
time the petition in this case was filed, petitioner resided in
California.
Petitioner is an attorney licensed to practice law in
California. Around 1993, petitioner became a named partner in
the law firm of Koletsky, Mancini, Feldman & Morrow (law firm) in
Los Angeles, specializing in insurance defense. Petitioner’s
draw from the law firm was $16,000 per week in 1996 and $18,000
per week in 1997.
Petitioner’s Marriage to Ms. Trevino and Personal Finances
Petitioner and Ms. Trevino were married on March 4, 1990,
and had three children during their marriage. The children were
born in 1993, 1995, and 1996. When petitioner became a partner
in the law firm, Ms. Trevino became responsible for the family
finances due to petitioner’s increased work responsibilities.
Generally, petitioner would sign his paycheck and turn it over to
Ms. Trevino, who would pay the family’s bills and expenses.
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