MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined, inter alia, that petitioner's claim for a refund of tax paid for 1983 and 1984, based on her claim for relief from joint liability for tax under section 6015(f) for 1983 and 1984, was not timely. Petitioner filed a petition under section 6015(e)(1) seeking review of that determination.
The sole issue for decision is whether petitioner's claim for a refund of tax...
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