MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
This proceeding was commenced under section 6015 for review of respondent's determination that petitioner is not entitled to relief from joint and several liability for 1996 and 1997 with respect to joint returns filed with his former spouse, Lauren Trevino (Ms. Trevino). The issue for decision is whether respondent abused his discretion in denying petitioner relief from joint and several liability under...
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