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entered is not reviewable by any other court, and this opinion
should not be cited as authority.
In a final notice of determination, dated April 9, 2003,
respondent denied petitioner’s claim for section 6015(f) relief
from her unpaid 1995, 1996, and 1997 Federal income tax
liabilities. In a timely petition, filed June 24, 2003,
petitioner requests this Court to review respondent’s
determination. Our jurisdiction to do so is established by
section 6015(e), see Ewing v. Commissioner, 118 T.C. 494, 496-497
(2002), and we review respondent’s determination for abuse of
discretion. Butler v. Commissioner, 114 T.C. 276, 292-293
(2000).
The issue for decision is whether respondent’s failure to
relieve petitioner from unpaid Federal income tax liabilities
reported on joint Federal income tax returns for the years 1995,
1996, or 1997 is, for any of those years, an abuse of discretion.
Background
Some of the facts have been stipulated and are so found. At
the time the petition was filed in this case, petitioner resided
in Plainview, Texas.
Petitioner and Tommy J. James (petitioner’s former spouse)
had been married for 19 years prior to their divorce in January
1998. They have two sons, Russell Blake James, born December 2,
1981, and Tyler Martin James, born June 25, 1985 (the children).
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