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SIMON v. COMMISSIONER

Docket No. 20258-04.

90 T.C.M. 302 (2005)

T.C. Memo. 2005-220

Eleanor Simon v. Commissioner.

United States Tax Court.

September 21, 2005.

Attorney(s) appearing for the Case

Jeffrey A. Collins, for petitioner;

Steven M. Webster, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge:

This case arises from a request for equitable relief (relief) under section 6015(f)1 with respect to petitioner's taxable year 1998. We must decide whether respondent abused respondent's discretion in denying petitioner such relief. We hold that respondent did not abuse respondent's discretion.

FINDINGS OF FACT

Some of the facts have been stipulated and...

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