MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioner petitioned the Court under section 6015(e) to redetermine respondent's determination that he is not entitled to equitable relief under section 6015(f) for 1994 and 1995. We decide whether petitioner is entitled to such relief. We hold he is not. Section references are to the applicable versions of the Internal Revenue Code. Dollar amounts are rounded.
FINDINGS OF FACT
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