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
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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Last modified: November 10, 2007