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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 December 18, 2003,
respondent denied petitioner’s claim for section 6015(f) relief
from her unpaid 1995 Federal income tax liability. In a timely
petition, filed March 3, 2004, 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, see Butler v.
Commissioner, 114 T.C. 276, 292-293 (2000).
The issue for decision is whether respondent’s failure to
relieve petitioner from an unpaid Federal income tax liability
reported on a 1995 joint Federal income tax return is 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 Camano Island, Washington.
Petitioner, a high school graduate with 2 years of college
education, married Jessie Bright (petitioner’s former spouse) in
1978. They have one child, a son, born in 1981.
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