- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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