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MERENDINO v. COMMISSIONER

Dkt. No. 8265-04.

91 T.C.M. 646 (2006)

T.C. Memo. 2006-2

Phyllis J. Merendino v. Commissioner.

United States Tax Court.

January 3, 2006.

Attorney(s) appearing for the Case

C. Page Hamrick III, for petitioner;

Stephen J. Neubeck, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GOEKE, Judge:

Petitioner challenges respondent's April 2004 determination that she is not entitled to equitable relief from joint and several liability under section 6015(f)1 for petitioner's taxable year 1996. The issue for decision is whether respondent abused his discretion in denying petitioner such relief. We hold that he did not.

FINDINGS OF FACT

Some of the facts...

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