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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