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was not entitled to any relief from joint and several liability
under section 6015. Petitioner timely filed a petition seeking
review of respondent’s determination. The issue for decision is
whether respondent’s denial of relief under section 6015(f) was
an abuse of discretion.
FINDINGS OF FACT
Some of the facts have been stipulated. We incorporate the
stipulated facts into our findings by this reference. Petitioner
resided in Tacoma, Washington, when her petition in this case was
filed.
Background
During the years in issue, petitioner was married to Thomas
W. Cowdery (Mr. Cowdery). In May 1997, petitioner and Mr.
Cowdery divorced.
Petitioner is a high school graduate and has completed some
college course work. During the years in issue, petitioner
identified her occupation as either child care provider or
teacher. Mr. Cowdery changed jobs frequently while married to
petitioner, working in construction, drafting, and pyrotechnics.
During their marriage, petitioner and Mr. Cowdery maintained
a joint bank account, and they discussed their household bills.
Mr. Cowdery, however, generally handled their household finances.
During the years at issue, petitioner was not aware of any
problems with Mr. Cowdery’s handling of their finances, but in
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