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 1999 with respect to a joint return filed with Steven F. Ohrman (Mr. Ohrman). The issues for decision are: (1) Whether petitioner is eligible for relief from joint and several liability under section 6015(b); (2) whether petitioner is...
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