ESTATE OF PROBINSKY v. COMMISSIONER

Docket No. 844-85.

55 T.C.M. 1546 (1988)

T.C. Memo. 1988-371

Estate of David Probinsky, Deceased, Brent Probinsky, Personal Representative, and Marci Probinsky v. Commissioner.

United States Tax Court.

Filed August 15, 1988.


Attorney(s) appearing for the Case

David A. Gradwohl, for the petitioner Marci Probinsky. Richard A. Josepher, for the petitioner Estate of David Probinsky. David A. Breen, for the respondent.


Memorandum Findings of Fact and Opinion

WILLIAMS, Judge:

The Commissioner determined a deficiency in petitioners' Federal income tax for the taxable year 1980 in the amount of $36,502. The issue we must decide is whether petitioner Marci Probinsky qualifies for relief from joint and several liability, pursuant to section 6013(e),1 for the deficiency determined by respondent.

Findings of Fact

Some of the facts...

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