- 2 - entered is not reviewable by any other court, and this opinion should not be cited as authority. This is a so-called stand alone innocent spouse case arising under section 6015(f). Petitioner applied for relief from joint tax liability for the 1997 taxable year. Respondent determined that petitioner was not entitled to such relief. Petitioner filed a timely petition under section 6015(e). Intervenor, petitioner’s former husband, filed a Notice of Intervention under Rule 325(b) and opposes such relief. The issue is whether respondent’s denial of relief under section 6015(f) was an abuse of discretion. Petitioner resided in Cocoa, Florida, at the time the petition was filed. Background The facts may be summarized as follows. During 1997, petitioner and intervenor were married. Petitioner was employed by Ameripath Florida, Inc., and had wage income of $41,823.25 during 1997. Intervenor lost his job in early 1997, and in August 1997 he decided to return to school for further education. He also took a part-time job at Sea World of Florida, Inc., earning approximately $7 per hour. In order to help pay their living expenses and accumulated debts, intervenor withdrew $14,363 from an individual retirement account (IRA). Petitioner and intervenor were divorced in January 1998. For the taxable year 1997, petitioner and intervenor filed aPage: Previous 1 2 3 4 5 6 7 Next
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