- 2 - 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 NorthernPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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