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her request for relief from joint and several liability pursuant
to section 6015. After concessions, the sole issue for decision
is whether respondent abused his discretion in denying
petitioner’s request for relief from joint and several tax
liability pursuant to section 6015 as to 1983.
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect at all relevant times, and
amounts are rounded to the nearest dollar.
FINDINGS OF FACT
Some facts have been stipulated and are so found. The
stipulation of facts, with accompanying exhibits, is incorporated
herein by this reference.
Petitioner and Mr. Hendricks (collectively, the Hendrickses)
were residents of the State of Colorado at all times relevant to
this case. The Hendrickses have been married for more than 45
years and have at all times filed joint Federal income tax
returns; i.e., Form 1040, U.S. Individual Income Tax Return.
Both petitioner and Mr. Hendricks are more than 70 years of age
and are retired. Before the Hendrickses married, they agreed to
separate their responsibilities, deciding that petitioner would
run the household while Mr. Hendricks would be responsible for
their finances.
Mr. Hendricks worked as a farm manager and a farm and ranch
real estate broker, and he invested in real estate. Mr.
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