MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
This case was commenced in response to respondent's denial of petitioner's request for relief under section 6015(f) with respect to unpaid taxes on a joint return filed by petitioner and her former spouse for 1998, 1999, 2000, and 2001. The liability for 1998 has been paid in full, and petitioner is not seeking a refund of any payments she has made toward the tax liability for that year. The remaining...
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