MEMORANDUM OPINION
NIMS, Judge:
Respondent determined that petitioner is not entitled to relief from joint and several liability for tax under section 6015(f) for 1986 and 1987. Petitioner filed a petition under section 6015(e)(1) seeking review of respondent's determination. The parties agree that petitioner would be eligible for relief under section 6015(f) if refund or credit of a resulting overpayment were not statutorily barred. The issue for decision...
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