Janet H. Krasner, Petitioner, and Paul Krasner , Intervenor - Page 41

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                         parties’ unemancipated children, the chil-                   
                         dren’s private school tuition, summer camp,                  
                         and daycare expenses.                                        
                    3.   Unreimbursed Medical and Dental expenses,                    
                         including, but not limited to, psychological                 
                         and/or psychiatric expenses on behalf of the                 
                         children, which exceed $250.00 dollars per                   
                         child per year, shall be apportioned 41%                     
                         plaintiff and 59% Defendant.                                 
                    4.   Plaintiff shall be responsible for payment of                
                         the first mortgage, second mortgage, and real                
                         estate taxes for the property located at 350                 
                         Exeter Rd., Haverford, PA.                                   
                    5.   All past issues related to credits sought by                 
                         Defendant and/or challenged by Plaintiff by                  
                         virtue of Defendant’s past payment of mort-                  
                         gage, taxes, and insurance, during any period                
                         of wife’s responsibility for payment thereof,                
                         shall be addressed in the context of the                     
                         equitable distribution of marital assets.                    
                         [Reproduced literally.]                                      
                                      OPINION                                         
               We review respondent’s denial of relief under section                  
          6015(f) for abuse of discretion.22  Butler v. Commissioner, 114             
          T.C. 276, 292 (2000).  Petitioner bears the burden of proving               
          that respondent abused respondent’s discretion in denying such              
          relief.  See Jonson v. Commissioner, 118 T.C. 106, 125 (2002),              
          affd. 353 F.3d 1181 (10th Cir. 2003).                                       
               Section 6015(f) grants respondent discretion to relieve an             
          individual who files a joint return from joint and several                  

               22The Court’s jurisdiction in this case is dependent upon              
          sec. 6015(e)(1).  Ewing v. Commissioner, 118 T.C. 494, 498-507              
          (2002); see also Fernandez v. Commissioner, 114 T.C. 324, 330-331           
          (2000); Butler v. Commissioner, 114 T.C. 276, 289-290 (2000).               




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