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 for any portion of the unpaid interest resulting from an understatement of tax on a joint return filed with her former husband for 1989. The issues for decision are: (1) Whether petitioner is eligible for relief from joint and several liability...
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