T.C. Memo. 2005-201
UNITED STATES TAX COURT
RUTH E. NEAL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8506-03. Filed August 22, 2005.
J. Larry Broyles, for petitioner.
Edwina L. Jones, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge: The issue for decision is whether petitioner
is entitled to equitable relief from joint and several liability
under section 6015(f) with respect to the following unpaid
Federal income taxes that are attributable to income earned by
petitioner’s former spouse as an anesthesiologist:
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