Francenia M. Griffin - Page 3

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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.                                                        
               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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