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O'NEILL v. COMMISSIONER

Docket No. 17375-02.

88 T.C.M. 118 (2004)

T.C. Memo. 2004-183

Nancy M. O'Neill and Robert B. Wollow, Intervenor v. Commissioner.

United States Tax Court.

August 11, 2004.

Attorney(s) appearing for the Case

Nancy M. O'Neill, pro se.

Robert B. Wollow, pro se.

Thomas M. Rohall, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge.

Pursuant to section 6015(e) and Rule 321,1 petitioner seeks review of respondent's determination that she is not entitled to relief from joint and several liability on her 1998 joint return. The issue for decision is whether respondent's denial of relief under section 6015(f) was an abuse of discretion. On January 13, 2003, Robert B. Wollow (Mr. Wollow), petitioner's former...

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