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LEVY v. COMMISSIONER

Dkt. No. 12846-02.

89 T.C.M. 1101 (2005)

T.C. Memo. 2005-92

Joan Phyllis Levy v. Commissioner.

United States Tax Court.

April 26, 2005.

Attorney(s) appearing for the Case

James S. Caris, for petitioner.

Timothy R. Maher, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Chief Judge:

This case arises from petitioner's request for relief from joint and several liability under section 6015 for 1979, 1991, 1992, 1993, 1994, 1995, 1996, 1997, 1998, and 1999.1 The issues for decision are: (1) whether petitioner is entitled to relief under section 6015(b) or (c) with respect to 1979; and (2) whether respondent abused his discretion in denying petitioner...

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