Judith A. Madden - Page 2

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          petitioner reported on a joint return filed with her husband,               
          David R. Sturges.  Petitioner filed a petition under section                
          6015(e)(1) seeking review of respondent’s determination.  We must           
          decide whether respondent abused his discretion in denying                  
          petitioner such relief.                                                     
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.                                      
               When the petition in this case was filed, petitioner resided           
          in Carlisle, Massachusetts.  Petitioner and Mr. Sturges have been           
          married since 1977.  Mr. Sturges has never abused petitioner.               
          Petitioner and Mr. Sturges have two daughters.  The younger                 
          daughter graduated from high school in May 2000 and began college           
          that September.                                                             
               Petitioner has a bachelor’s degree in art history and a                
          master’s degree in biology.  Petitioner is 64 years old and                 
               Petitioner was not employed outside the home for most years            
          after she married Mr. Sturges.  She had no earnings subject to              
          withholding for Social Security from 1980 to 1985, 1991 to 1994,            
          and 1998 to the present.  She had earnings subject to withholding           
          for Social Security of $3,084 in 1986, $2,060 in 1987, $129 in              

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