T.C. Memo. 2003-18
UNITED STATES TAX COURT
PATRICIA BARRANCO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 819-01, 820-01. Filed January 21, 2003.
Neil V. Birkhoff, for petitioner.
Dustin M. Starbuck, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge: In these consolidated cases, petitioner
seeks relief from joint and several liability under section
6015(b) and (f) with respect to joint returns that she and her
husband filed for 1983 through 1992.1
1 References to secs. 6015 and 7491 are to those sections as
added to the Internal Revenue Code by the Internal Revenue
Service Restructuring and Reform Act of 1998 (RRA 1998), Pub. L.
105-206, secs. 3001(a) and 3201, 112 Stat. 726, 734. Unless
(continued...)
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