- 19 -
As we held above, petitioner failed to meet the requirements of
section 274(d). According, we hold for respondent on this issue.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.4
4 The decision to be entered herein shall reflect that
petitioner Dorothy Morris is entitled to relief from joint
liabilities determined for 1996 and 1997 pursuant to sec.
6015(b).
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Last modified: May 25, 2011