Susan L. Abelein - Page 2

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          petitioner was not entitled to any relief under section 6015.               
          Petitioner timely filed a petition seeking review of respondent’s           
          determination.  After concessions,2 the issue for decision is               
          whether petitioner is entitled to relief under section 6015(b) or           
          (f) for 1982, 1983, 1984, 1985, and 1986.                                   
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The first, second, and third stipulations of facts are                      
          incorporated herein by this reference.  Petitioner resided in               
          Boring, Oregon, when her petition in this case was filed.                   
          Petitioner’s Education                                                      
               Petitioner attended 1 year of college and then enrolled in a           
          1-year licensed practical nurse (LPN) program.  Petitioner                  
          graduated from the program and worked as an LPN for several                 
          years.  Petitioner eventually attended a registered nursing (RN)            
          program and is currently employed as an RN.  Petitioner has                 
          worked as an RN in triage, dermatology, internal medicine,                  
          obstetrics and gynecology, and hospice care.  Petitioner has                
          never taken any courses in finance, bookkeeping, or tax.                    


               2At trial, the Court reserved ruling on Exhibit 243-P and              
          ordered the parties to brief the issue of its admissibility.  In            
          his opening brief, respondent conceded the admissibility of                 
          Exhibit 234-P.  From the descriptions of the exhibit in the                 
          transcript and the brief, and based on our review of Exhibits               
          234-P and 243-P, however, it is clear respondent intended to                
          concede the admissibility of Exhibit 243-P.  Consequently, we               
          shall treat respondent’s concession on brief as a concession with           
          respect to Exhibit 243-P.                                                   




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