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The cases arise from petitioner’s election to seek relief
from joint and several liability under section 6015 for Federal
income taxes for 1996 and 1997. Respondent issued to petitioner
notices of determination that she is not entitled to relief under
section 6015(f).
The issue for decision is whether respondent’s determination
for each year that petitioner is not entitled to relief under
section 6015(f) is an abuse of discretion.
Background
The stipulated facts and the exhibits received into evidence
are incorporated herein by reference. At the time the petitions
in these cases were filed, petitioner resided in Anthony,
Florida.
Petitioner filed her 1996 Federal income tax return jointly
with her then husband, Mark J. Martin (husband), on February 12,
1998. Her joint Federal income tax return for 1997 was filed
shortly thereafter, on April 15, 1998. Both returns were filed
without remittance. It does not appear that petitioner
significantly benefited from the failure to pay tax beyond normal
support.
Petitioner and her husband received a judgment of
dissolution of marriage in Illinois on April 27, 2002.
Petitioner sent to respondent a Form 8857, Request for Innocent
Spouse Relief, dated October 6, 2003.
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