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DEIHL v. COMMISSIONER

Docket No. 22897-08.

134 T.C. 156 (2010)

SARI F. DEIHL, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed February 23, 2010.

Attorney(s) appearing for the Case

Tim A. Tarter and Kirk A. McCarville , for petitioner.

Anne W. Durning , for respondent.

OPINION

VASQUEZ, Judge:

Petitioner seeks review of respondent's determination that she is not entitled to relief from joint and several liability under section 6015(b), (c), and (f)1 with respect to her joint Federal income tax liabilities for 1996, 1997, and 1998. Our jurisdiction to review petitioner's request for relief is conferred by section 6015(e). The only issue for decision is whether petitioner is precluded by...

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