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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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