Teresa G. Butner - Page 5




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          legislative developments relating to our jurisdiction under                 
          section 6015(e)(1) to review such a denial.                                 
               We have also made editorial, stylistic, clarifying, and                
          organizational changes to the Special Trial Judge’s recommended             
          findings of fact and conclusions of law.                                    
               We conclude that the recommended findings of fact and                  
          conclusions of law of Special Trial Judge Stanley J. Goldberg, as           
          modified and set forth below, should be adopted as a report of              
          the Court.                                                                  
               This case arose from petitioner’s request for relief under             
          section 6015 for each of the taxable years 1994, 1995, 1998, and            
          1999.  We hold that we have jurisdiction to review respondent’s             
          denial of relief under section 6015(f) for each of those years.             
          We further hold that respondent did not abuse respondent’s                  
          discretion in denying petitioner relief under that section for              
          each of the taxable years 1994, 1995, 1998, and 1999.                       
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found                
          except as stated herein.                                                    
               Petitioner resided in Hickory, North Carolina, on the date             
          she filed the petition in this case.                                        
               Petitioner and her spouse, Mr. Butner, were married in 1984            
          and were still married at the time of the trial.                            
               During 1994, 1995, 1998, and 1999, petitioner lived on a               







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