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DOYEL v. COMMISSIONER

Docket No. 9138-02.

87 T.C.M. 960 (2004)

T.C. Memo. 2004-35

Verna Doyel v. Commissioner.

United States Tax Court.

Filed February 10, 2004.

Attorney(s) appearing for the Case

Terri A. Merriam, Wendy S. Pearson, and Jennifer A. Gellner, for the petitioner.

Margaret A. Martin, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined that petitioner did not qualify for relief from joint and several liability pursuant to section 6015(b), (c), or (f).1 The issue for decision is whether petitioner is entitled to relief from joint and several liability pursuant to section 6015(b) or (f) for 1982, 1983, 1984, 1985, and 1986.2

FINDINGS OF FACT

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