T.C. Memo. 2001-313
UNITED STATES TAX COURT
SYBIL M. SMITH, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 144-00. Filed December 19, 2001.
William Burwell Sellers, for petitioner.
Linda J. Wise, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: This is a proceeding commenced under section
6015, based on respondent’s determination that petitioner is not
entitled to relief from joint and several liability for 1987,
1992, and 1995 with respect to joint returns filed with Hugh V.
Smith, Jr. (H. Smith). Petitioner has now conceded that she is
not entitled to relief for 1995 because she was not a party to a
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