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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 involves innocent spouse relief for the amount of
tax shown as due on petitioner and her then husband’s joint 1999
income tax return that has not been fully paid. Petitioner
contends that respondent’s allowance of only partial innocent
spouse relief was an abuse of discretion. Consequently, we must
decide whether respondent abused his discretion in denying
petitioner innocent spouse relief under section 6015(f) for $1,815
of the $7,100 shown as the amount owed on the 1999 return.
Background
Some of the facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference. At the time of filing the petition,
petitioner resided in Houston, Texas.
Petitioner and her husband at that time, Todd Meadows, timely
filed a joint Form 1040, U.S. Individual Income Tax Return, for
1999. They reported Mr. Meadows’s wage income of $51,825.97 and
petitioner’s wage income of $39,455.81, together with other income
items such as a taxable distribution from a pension plan, interest
income, and dividend income. Their total income for 1999 was
shown as $107,208. The total tax shown was $20,395, with $7,100
owed (including a $256 estimated tax penalty).
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