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DEIHL v. COMMISSIONER OF INTERNAL REVENUE

Nos. 12937-06, 22897-08

T.C. Memo. 2012-176

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

United States Tax Court.

Filed June 21, 2012.

Attorney(s) appearing for the Case

Tim Alan Tarter , for petitioner.

Anne Ward Durning , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge:

These consolidated cases arise from petitioner's requests for section 60151 relief with respect to the 1996-99 Federal income tax liabilities of petitioner and her deceased husband, Joseph Deihl. Respondent determined that petitioner was not entitled to relief under section 6015. Petitioner timely filed petitions seeking review of respondent's determination. After concessions...

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