T.C. Memo. 2002-142
UNITED STATES TAX COURT
SUSAN L. CASTLE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10195-00. Filed June 6, 2002.
Gino Pulito, for petitioner.
Katherine Lee Kosar and Dennis G. Driscoll, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: This case arises from a request for equita-
ble relief (relief) under section 6015(f)1 with respect to peti-
tioner’s taxable year 1993. We must decide whether respondent
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at all relevant times. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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