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be entered is not reviewable by any other court, and this opinion
should not be cited as authority.
Pursuant to the provisions of section 6015, petitioner made
an administrative request for relief from Federal income tax
liabilities for the taxable years 1994, 1995, 1996, 1997, and
1998. Respondent denied petitioner’s request for relief in a
notice of determination issued on October 11, 2002. Petitioner
timely filed a petition with this Court under section 6015(e) for
review of respondent’s determination. Intervenor, petitioner’s
former husband, filed a Notice of Intervention under Rule 325(b)
and opposes such relief.
The sole issue for decision is whether respondent abused his
discretion in denying petitioner relief from joint and several
liability under section 6015(f). We hold that he did.
Background
Some of the facts have been stipulated, and they are so
found. Petitioner resided in Berkeley, California, at the time
that her petition was filed with the Court.
Petitioner and intervenor David Browda (intervenor) were
married to each other on March 22, 1970, and had one child, a
daughter, during their marriage. In or about 1972, petitioner
and intervenor jointly purchased a home in which they resided
throughout their marriage.
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