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joint and several liability for Federal income tax for
petitioner’s 1999 taxable year. Petitioner made such request by
submitting a Form 8857, Request for Innocent Spouse Relief, dated
March 28, 2001 (the request). Respondent denied the request by
notice of determination dated January 21, 2003. On April 23,
2003, petitioner timely filed a petition for review of
respondent’s determination (the petition). On September 23,
2003, Judy H. Scarborough Barrentine, petitioner’s former wife
(intervenor), timely elected to intervene in this proceeding.
The sole issue before us is whether respondent abused his
discretion in denying the request. We conclude that he did not.
The decision to be entered is not reviewable by any other court,
and this opinion should not be cited as authority.
Background
Some facts have been stipulated and are so found. The
stipulation of facts, with accompanying exhibits, is incorporated
herein by this reference.
At the time the petition was filed, petitioner resided in
Yazoo City, Mississippi.
Petitioner and intervenor made a joint return of Federal
income tax (the return) for their 1999 taxable (calendar) year.
The return shows gross income of $82,580, of which only $19,977
(24 percent) is attributable to intervenor. The return also
shows total tax due of $14,972 and withholding credits of $3,431,
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