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The case arises from petitioner’s election to seek relief
from joint and several liability for Federal income tax for
petitioner’s 1999 taxable year under section 6015. Respondent
determined that petitioner is not entitled to relief under
section 6015(b), (c), or (f).
The issues for decision are whether petitioner is entitled
to relief under section 6015(b) or (c) and whether respondent’s
determination that petitioner is not entitled to relief under
section 6015(f) is an abuse of discretion.
Background
Most of the facts are stipulated. The stipulated facts and
the exhibits received into evidence are incorporated herein by
reference. At the time the petition in this case was filed,
petitioner resided in Cleburne, Texas.
During 1999 petitioner was married to Mr. Jerry Jorgensen
(Jorgensen). Petitioner has a college degree and was employed as
the manager of a medical office. Jorgensen is a high school
graduate and was employed by G.K. Carlile, Inc. as a
“serviceman”. Jorgensen started his own business in 1993; the
business failed; and in 1999 only an open bank account remained.
Petitioner and Jorgensen maintained a joint checking account
into which they deposited all their wage income. Petitioner not
only wrote most of the checks drawn on the account, but she also
reviewed the bank statements and balanced the checkbook.
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