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years 1989, 1991, 1992, and 1993 and (2) a request for relief
under section 6015(f) with respect to petitioner’s taxable year
1990.
The issues for decision are:
(1) Is petitioner entitled to relief under section 6015(b)
with respect to each of the taxable years 1989, 1991, 1992, and
1993? We hold that petitioner is not entitled to such relief.
(2) Did respondent abuse respondent’s discretion in denying
petitioner relief under section 6015(f) with respect to each of
the taxable years 1989, 1990, 1991, 1992, and 1993? We hold that
respondent did not abuse respondent’s discretion.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time petitioner filed the petition, she resided in
Jeanette, Pennsylvania.
Petitioner received three degrees from the University of
Pittsburgh: (1) An undergraduate nursing degree in 1976; (2) a
graduate nursing degree in 1980; and (3) a law degree in 1990.
From 1976 until 1990, petitioner worked at Monsour Medical
Center, initially as a registered nurse in the critical care unit
and thereafter as the director of nursing.
In 1991, petitioner was admitted to practice law in Pennsyl-
vania and began to do so as a sole practitioner focusing on
family law and the respective laws relating to personal injury
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