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The decision to be entered is not reviewable by any other court,
and this opinion should not be cited as authority.
Respondent granted, in part, petitioner’s request for
section 6015 relief with respect to unpaid assessments of $27,714
in Federal income tax and a section 6662(a) accuracy-related
penalty of $1,162 assessed against petitioner and Darrin W.
Champagne (intervenor) for 2000. The issue for decision is
whether petitioner is entitled to relief from joint and several
liability under section 6015(b), (c), or (f) in excess of the
amount determined by respondent.
Background
The stipulated facts and the exhibits received into evidence
are incorporated herein by reference. At the time the petition
in this case was filed, petitioner resided in Magnolia, Texas.
At the time the notice of intervention was filed, intervenor
resided in Pineland, Texas.
Petitioner and intervenor were married in 1993. The
marriage was dissolved by an agreed final decree of divorce,
filed in the district court of Texas, on March 1, 2002.
Petitioner has a bachelor’s degree in elementary education.
From January to April of 2000, petitioner was employed by the
Magnolia Independent School District as a teacher. Petitioner
stayed home for the remainder of 2000 to care for her newborn
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