SUTHERLAND v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 3634-18.

T.C. Memo. 2021-110

DONNA M. SUTHERLAND, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 16, 2021.


Attorney(s) appearing for the Case

David Michael Klemm , James H. Everett , and Craig E. Reeder , for petitioner.

Carlton W. King and Nina P. Ching , for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

Petitioner seeks review of the determination by the Internal Revenue Service (IRS or respondent) that she is not eligible for relief from joint and several liability for the 2005 and 2006 tax years. The sole question presented is whether she is eligible for such relief under section...

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