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are to the Internal Revenue Code as amended, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
This case arises from a request for relief under section
6015(f) with respect to petitioner’s joint income tax liabilities
for 1996 and 1997. No notices of deficiency were issued.
Petitioner filed Form 8857, Request for Innocent Spouse Relief
(And Separation of Liability and Equitable Relief), seeking
equitable relief under section 6015(f) for each year. Respondent
determined that petitioner was not entitled to relief under
section 6015(f) for either year.
The issue for decision is whether respondent abused his
discretion when he denied petitioner’s request for relief under
section 6015(f) for 1996 and 1997.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits received into evidence
are incorporated herein by reference. At the time the petition
was filed, petitioner resided in California.
During the years at issue, petitioner’s former husband,
David Velez (Dr. Velez), was a physician. Petitioner, trained as
a registered nurse, did not work outside of the home until 1997.
Dr. Velez was sued by a patient in 1994 and as a result was
dismissed from his employment.
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