Nora Aranda - Page 1

                                 T.C. Memo. 2003-306                                  

                               UNITED STATES TAX COURT                                

                             NORA ARANDA, Petitioner v.                               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5168-02.              Filed November 5, 2003.               

               Ruben Trey Arvizu III, for petitioner.                                 
               Michael L. Boman, for respondent.                                      

                                 MEMORANDUM OPINION                                   

               MARVEL, Judge:  This case arises from a request for relief             
          under section 60151 with respect to petitioner’s 1985 and 1986              
          taxable years.  Respondent determined that petitioner is entitled           
          to partial relief from joint and several liability under section            

               1All section references are to the Internal Revenue Code in            
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  

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