Amy A. Christman - Page 3




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          of section 7463(b), the decision to be entered is not reviewable            
          by any other court, and this opinion shall not be treated as                
          precedent for any other case.                                               
               This case arises from a request for innocent spouse relief             
          under section 6015(f) with respect to petitioner’s 1998 and 1999            
          taxable years.  No notice of deficiency was issued for either of            
          these years.  Petitioner requested relief by filing Form 8857,              
          Request for Innocent Spouse Relief, for the years 1997, 1998, and           
          1999.  In her application, petitioner sought relief under section           
          6015(f) and specifically stated she was not seeking relief under            
          section 6015(b) or (c).  Respondent determined that petitioner              
          was not entitled to relief under section 6015(f); thus, the issue           
          is whether respondent’s denial of relief under section 6015(f)              
          was an abuse of discretion with respect to petitioner’s taxable             
          years 1998 and 1999.3                                                       
                                     Background                                       
               The facts may be summarized as follows.  At the time the               
          petition was filed petitioner resided in Temple, Pennsylvania.              




               2(...continued)                                                        
          Internal Revenue Code as amended, and all Rule references are to            
          the Tax Court Rules of Practice and Procedure.                              
               3  The record is unclear as to the status of petitioner’s              
          request for relief for taxable year 1997.  Neither the                      
          preliminary determination letter nor the notice of determination            
          addressed any request for relief for taxable year 1997.                     
          Moreover, in her petition to this Court, petitioner only                    
          requested a review of the denial of relief for taxable years 1998           
          and 1999.  The year 1997, therefore, is not before the Court.               



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