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income tax liability. That liability is based in part on an
unpaid liability reported on a timely filed joint 1992 Federal
income tax return, and in part upon a deficiency determined and
assessed several years later. Petitioner’s request was denied in
a notice of final determination issued by respondent on February
21, 2001. She timely petitioned this Court for review of
respondent’s determination. See sec. 6015(e).
The issue for decision is whether respondent’s refusal to
relieve petitioner from liability under section 6015 with respect
to a 1992 Federal income tax liability is an abuse of discretion.
We hold that it was not, but for a reason other than that
advanced by respondent.
Background
Some of the facts have been stipulated and are so found. At
the time the petition was filed, petitioner resided in Roanoke,
Virginia.
Petitioner and Peter Stimeling (Mr. Stimeling) were married
to each other on June 9, 1990. They separated in February 1993
and were divorced on October 25, 1994. During 1992, petitioner
and Mr. Stimeling worked together as employees of Valley View
Associates, Ltd. Each received a Form W-2, Wage and Tax
Statement, for that year on which the following information is
reported:
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