T.C. Memo. 2002-144
UNITED STATES TAX COURT
SANDRUS L. COLLIER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1570-01. Filed June 10, 2002.
Eric F. Horvitz and Elizabeth A. Keith, for petitioner.
Michele A. Yates, 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 years 1987 through 1991.
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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