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Respondent determined that petitioner is not entitled to
relief from joint and several liability for tax under section
6015(f) for tax years 1992, 1993, 1994, 1995, 1996, 1997, and
1998 with respect to joint returns filed with Graylyne Griffin.
Petitioner filed a petition under section 6015(e)(1) seeking
review of respondent’s determination.
The issue for decision is whether respondent’s denial of
petitioner’s request for relief pursuant to section 6015 was an
abuse of discretion.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in San
Antonio, Texas, on the date the petition was filed in this case.
Petitioner and her former spouse, Graylyne H. Griffin (Mr.
Griffin), were married in 1981. From the time that they were
first married, petitioner and Mr. Griffin usually filed their
Federal income tax returns jointly. During their marriage,
between 1996 and 1998, petitioner obtained an associate’s degree
in applied science at Saint Phillips College. Since obtaining an
associate’s degree, petitioner has been employed as a certified
occupational therapy assistant. Petitioner and Mr. Griffin
ceased living together on March 12, 2001. Petitioner’s and Mr.
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