PETRANE v. COMMISSIONER

Docket No. 2011-07.

129 T.C. 1 (2007)

129 T.C. No. 1

GILDA A. PETRANE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 24, 2007.


Attorney(s) appearing for the Case

Sheryl D. King Richards, for petitioner.

Kristina L. Rico, for respondent.


OPINION

RUWE, Judge:

Petitioner timely filed a petition under section 6015(e)1 seeking review of respondent's final determinations denying her relief from joint and several liability under section 6015 for the tax years 1996, 1997, 1998, 1999, 2000, and 2002. Petitioner requested that this case be conducted under section 7463, which provides for "small tax case" or "S case" procedures...

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