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ROSENTHAL v. COMMISSIONER

Docket. No. 2601-01.

87 T.C.M. 1183 (2004)

T.C. Memo. 2004-89

Catherine Rosenthal v. Commissioner.

United States Tax Court.

Filed March 26, 2004.

Attorney(s) appearing for the Case

William O. Lenihan, for the petitioner.

Theresa G. McQueeney, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HALPERN, Judge:

Pursuant to the provisions of section 6015,1 petitioner applied for relief from joint and several liability for the 1996 taxable year by submitting a Form 8857, Request for Innocent Spouse Relief, dated July 25, 1999. Respondent denied petitioner's request for relief pursuant to a notice of determination dated December 21, 2000 (the notice of determination). The notice of...

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