Connie A. Washington v. Commissioner

Jacobs, Judge:

Respondent determined that petitioner is not entitled to relief from joint liability for tax under section 6015(f) for 1989 with respect to a joint return filed with Kenneth Washington. 1 Petitioner filed a petition under section 6015(e)(1) seeking review of respondent’ determination.

The issues for decision are (1) whether respondent’s denial of petitioner’s request for relief pursuant to section 6015(f) was an abuse of discretion, and, if so, (2) whether petitioner is entitled to a refund of all amounts paid/applied toward the tax shown as owed on the 1989 joint return.

FINDINGS…