Debra Anne Banderas - Page 2
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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
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.
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Last modified: November 10, 2007