Jacquelyn Brown - Page 1

                                 T.C. Memo. 2002-187                                  

                               UNITED STATES TAX COURT                                

                           JACQUELYN BROWN, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5978-00.              Filed August 5, 2002.                 

               Jacquelyn Brown, pro se.                                               
               Richard A. Stone, for respondent.                                      

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               COLVIN, Judge:  Petitioner filed a Form 8857, Request for              
          Innocent Spouse Relief, in which she sought relief from joint and           
          several liability for tax years 1988-90.  Respondent determined             
          that petitioner is not entitled to relief from joint and several            
          liability under section 6015(b), (c), or (f).  Petitioner filed a           
          petition under section 6015(e)(1) in which she contended that she           

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