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not entitled to relief from joint and several liability on her
1998 joint return. The issue for decision is whether
respondent’s denial of relief under section 6015(f) was an abuse
of discretion. On January 13, 2003, Robert B. Wollow (Mr.
Wollow), petitioner’s former spouse, filed a notice of
intervention with the Court, challenging petitioner’s entitlement
to relief from joint and several liability. See Rule 325.
FINDINGS OF FACT
Some of the facts have been stipulated. We incorporate the
stipulated facts into our findings by this reference. Petitioner
resided in Santa Rosa, California, when she filed her petition in
this case.
Background
Petitioner and Mr. Wollow became legally separated in
December 1997 and divorced in February 1999. Petitioner has a
bachelor’s degree in business administration. During 1998, after
her employment as the director of human resources for a mortgage
banking company was terminated, petitioner was employed at a
lumber company for approximately 1 month. Thereafter, in 1998,
petitioner worked as a human resources manager for a software
company. Meanwhile, Mr. Wollow was employed as an airline pilot.
Petitioner’s Bankruptcy and the 1998 Joint Income Tax Return
On April 7, 1999, petitioner filed a chapter 7 bankruptcy
petition with the United States Bankruptcy Court for the Northern
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