Tony D. Ishizaki - Page 1

                                 T.C. Memo. 2001-318                                  

                               UNITED STATES TAX COURT                                

                          TONY D. ISHIZAKI, Petitioner, AND                           
                        RANG SUN PARK ISHIZAKI, Intervenor v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11358-99.          Filed December 27, 2001.                 

                    P and I filed a joint 1995 Federal income tax                     
               return.  Following examination, R determined that                      
               constructive dividend income from a furniture business                 
               operated by the spouses had been omitted on the 1995                   
               return.  After a joint notice of deficiency was issued                 
               to P and I, P filed a petition with this Court not                     
               challenging R’s determinations but seeking relief from                 
               joint and several liability.  I subsequently intervened                
               in the proceeding, disputing P’s entitlement to the                    
               relief sought.                                                         
                    Held:  P has failed to establish his entitlement                  
               to relief from joint and several liability pursuant to                 
               either subsec. (b) or subsec. (c) of sec. 6015, I.R.C.                 
               Joseph E. Diamond, for petitioner.                                     
               Mufthiha Sabaratnam, for intervenor.                                   
               David R. Jojola, for respondent.                                       

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