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petitioner’s request for equitable relief pursuant to section
6015(f) was an abuse of discretion.
The parties have submitted the instant case fully
stipulated, without trial, pursuant to Rule 122. The parties’
stipulations of fact are incorporated herein by reference and are
found as facts in the instant case.
At the time of filing her petition, petitioner resided in
Atlanta, Georgia.
During the years in issue, petitioner was married to James
George. Both petitioner and Mr. George held master’s degrees.
Petitioner was employed as a school teacher, and Mr. George was
employed by Georgia Power Company. In addition to his regular
employment, Mr. George entered a business venture in 1998 to
build and sell single-family homes.
Petitioner and Mr. George failed to timely file income tax
returns for 1994, 1995, 1996, 1997, and 1998. Mr. George,
however, periodically told petitioner that he had timely filed
the tax returns for those years and had paid the related tax
liabilities, and respondent concedes that petitioner believed Mr.
George had done so.
Mr. George died in October of 1999, and petitioner was
appointed to represent Mr. George’s estate. While assembling
financial records of the estate, petitioner discovered that tax
returns for 1994 through 1998 had not been filed. Therefore,
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