ALIOTO v. COMMISSIONER

Docket No. 14356-03.

92 T.C.M. 285 (2006)

T.C. Memo. 2006-199

Kathleen Sullivan Alioto, v. Commissioner.

United States Tax Court.

September 18, 2006.


Attorney(s) appearing for the Case

Karen L. Hawkins, for petitioner.

Michael E. Melone, Andrew R. Moore, and Davis G. Yee, for respondent.


MEMORANDUM OPINION

VASQUEZ, Judge:

Respondent determined that petitioner did not qualify for relief from joint and several liability for 1995 and 1996. The issue for decision is whether we have jurisdiction to decide whether petitioner is entitled to relief pursuant to section 6015(f).1

Background

Some of the facts have been stipulated. The stipulation of facts and the attached exhibits are incorporated...

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