T.C. Memo. 2002-285
UNITED STATES TAX COURT
JEANNE M. TRENT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7408-01. Filed November 20, 2002.
Richard P. Eisen, for petitioner.
Gary S. Stirbis, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: This proceeding was commenced under section
6015 for review of respondent’s determination that petitioner is
not entitled to relief from joint and several liability for 1994
with respect to a joint return filed with Steven Trent
(S. Trent). The issues for decision are whether petitioner is
barred from relief on the basis of res judicata under section
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