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 with respect to joint returns filed with Barry Trupin (Trupin) for 1982 through 1986. Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure...
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