Nancy M. O'Neill, Petitioner, and Robert B. Wollow, Intervenor - Page 2

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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.                                                                  
               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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