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FRIDAY v. COMMISSIONER

Docket No. 6325-04.

124 T.C. 220 (2005)

124 T.C. No. 13

PATRICIA M. FRIDAY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 12, 2005.

Attorney(s) appearing for the Case

Warren N. Nemiroff, for petitioner.

Valerie L. Makarewicz, for respondent.

OPINION

GERBER, Chief Judge:1

Respondent issued a notice of determination to petitioner denying her request for relief under section 60152 and specifically finding that she was ineligible for relief under section 6015(b), (c), or (f). Petitioner filed a petition with this Court seeking relief from joint and several liability. On October 12, 2004, respondent filed a motion for summary judgment...

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