- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION WHERRY, Judge: This case arises from a petition for judicial review filed in response to a determination concerning relief from joint and several liability under section 6015.1 The issue for decision is whether denial by respondent of petitioner’s request for relief from joint and several liability for the taxable years 1997 and 1999 constitutes an abuse of discretion. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulations of the parties, with accompanying exhibits, are incorporated herein by this reference. Petitioner married Julio C. Banderas (Dr. Banderas) in March of 1972. For most of their married life, the couple resided in Georgia, where Dr. Banderas practiced medicine, specializing in orthopedic surgery, and petitioner stayed at home caring for their children and children from a previous marriage of Dr. Banderas. Petitioner later returned to school and in 1993 completed a registered nursing degree. Throughout the relevant period and at the time of trial, petitioner was employed in the nursing field, often working multiple jobs. During their 1 Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, and Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007