- 5 - 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 aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007