MANNELLA v. COMMISSIONER OF INTERNAL REVENUE

No. 17531-07.

132 T.C. No. 10

DENISE MANNELLA, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court

Filed April 13, 2009.


Attorney(s) appearing for the Case

Denise Mannella, pro se.

Russell F. Kurdys, for respondent.


OPINION

HAINES, Judge.

This case is before the Court on respondent's motion for summary judgment. Petitioner brought this action under section 6015 seeking relief from joint and several liability for unpaid taxes.1

Background

Petitioner resided in Pennsylvania at the time her petition was filed.

Petitioner and her husband, Anthony J. Mannella, filed joint Federal income tax returns for the years 1996...

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