Zenobia Elisia Clary Ziegler - Page 2

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          discretion in denying petitioner relief under section 6015(f) for           
          the taxable year 1998.                                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts is incorporated herein by this                     
          reference.  Petitioner resided in Lake Ridge, Virginia, when she            
          filed the petition in this case.                                            
               Petitioner was married to John L. Ziegler, Jr. (Mr.                    
          Ziegler), from 1990 until March 7, 2000.  Petitioner separated              
          from Mr. Ziegler in February 1999.  Petitioner earned her                   
          bachelor’s degree from Virginia State University.  During 1998,             
          petitioner was employed by the Commonwealth of Virginia and                 
          Suffolk County Schools, and Mr. Ziegler was employed as a U.S.              
               Petitioner and Mr. Ziegler filed electronic joint Federal              
          income tax returns for 1995, 1996, and 1997.  In anticipation of            
          filing a joint return with Mr. Ziegler for 1998, petitioner gave            
          Mr. Ziegler her 1998 W-2, Wage and Tax Statements, which showed             
          taxable income of $1,159 from Suffolk Public Schools and $1,680             
          from the Commonwealth of Virginia.  Mr. Ziegler subsequently                
          returned the W-2 statements to petitioner and informed her that             
          he would file a separate income tax return because petitioner did           
          not make enough money to require the filing of a return.                    
          However, without petitioner’s knowledge, Mr. Ziegler arranged for           

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