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and 1999.1 The issues for decision are: (1) whether petitioner
is entitled to relief under section 6015(b) or (c) with respect
to 1979; and (2) whether respondent abused his discretion in
denying petitioner relief under section 6015(f) with respect to
each of petitioner’s taxable years 1979, 1991, 1992, 1993, 1994,
1995, 1996, 1997, 1998, and 1999.
FINDINGS OF FACT2
A. Background
At the time her petition was filed petitioner resided in
Miami-Dade County, Florida. Petitioner received a bachelor of
arts degree in elementary education in 1969. Shortly after
obtaining her bachelor’s degree, petitioner worked as a
substitute teacher for approximately a year.
Petitioner and her former husband, Dr. Mitchell Levy (Levy),
married during 1974. Petitioner and Levy had three children
1 References to sec. 6015 are to that section as added to
the Internal Revenue Code by the Internal Revenue Service
Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3201,
112 Stat. 734. Sec. 6015 generally applies to any liability for
tax arising after July 22, 1998, and any liability for tax
arising on or before July 22, 1998, that remains unpaid as of
such date. See Cheshire v. Commissioner, 115 T.C. 183, 189
(2000), affd. 282 F.3d 326 (5th Cir. 2002); H. Conf. Rept. 105-
599, at 251 (1998), 1998-3 C.B. 747, 1005. All other section
references, unless otherwise indicated, are to the Internal
Revenue Code in effect for the years in issue.
2 Some of the facts have been stipulated and are found
accordingly.
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