Cynthia Emery Weight - Page 2

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                               OPINION OF THE SPECIAL TRIAL JUDGE                                       
                  CARLUZZO, Special Trial Judge:  In a final notice of                                  
            determination, dated March 8, 2001, respondent denied                                       
            petitioner’s claim for section 6015(f) relief from her unpaid                               
            1996 Federal income tax liability.  In a timely petition, filed                             
            May 24, 2001, petitioner requests this Court to review                                      
            respondent’s determination.  Our jurisdiction to do so is                                   
            established by section 6015(e), see Ewing v. Commissioner,                                  
            118 T.C. 494, 496-497 (2002), and we review respondent’s                                    
            determination for abuse of discretion, Butler v. Commissioner,                              
            114 T.C. 276, 292-293 (2000).                                                               
                  Some of the facts have been stipulated and are so found.  At                          
            the time the petition was filed in this case, petitioner resided                            
            in Hillsboro, Oregon.                                                                       
                  Petitioner and Ronald R. Weight were married on February 14,                          
            1992, they separated in 1997, and were divorced by a Stipulated                             
            Judgment of Dissolution of Marriage, effective February 26,                                 
            1998(the divorce decree).  They have one child, Aaron Cyrill                                
            Weight.2  Petitioner also has at least one other child, Sarah C.                            
            Weight, who presumably was a minor during 1996.  Mr. Weight is                              
            not the father of Sarah C. Weight.  In 1998, Sarah C. Weight                                

                  2  In the divorce decree, the date of birth for this child                            
            is listed as December 5, 1977.  We assume that the reference to                             
            1977 is an error.                                                                           

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