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be entered is not reviewable by any other court, and this opinion
should not be cited as authority.
Pursuant to the provisions of section 6015, petitioner made
an administrative request for relief from a 1996 Federal income
tax deficiency. Respondent denied petitioner’s request for
relief in a final notice of determination issued on July 11,
2002. Petitioner timely filed a petition with this Court under
section 6015(e) for review of respondent’s determination.
Intervenor, petitioner’s former wife, filed a Notice of
Intervention under Rule 325(b) and opposes such relief.
The sole issue for decision is whether respondent abused his
discretion in denying petitioner relief from joint and several
liability under section 6015(f). We hold that he did not.
Background
Some of the facts have been stipulated, and are so found.
Petitioner resided in Pitts, Georgia, at the time that his
petition was filed with the Court.
Petitioner and intervenor Jamie L. Jones (intervenor) were
married to each other on May 19, 1990, and had one child, a son,
during their marriage.
During 1996, petitioner worked as a full-time employee for
the City of Cordele and as a part-time employee for Gin Co., Inc.
Petitioner earned income of $13,855 and $3,206, respectively, at
each job in 1996.
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