- 41 - 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).Page: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
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