T.C. Memo. 2003-201
UNITED STATES TAX COURT
MARC S. FELDMAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14326-01. Filed July 10, 2003.
Stephen C. Mancini, for petitioner.
Elaine T. Fuller, 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 1996
and 1997 with respect to joint returns filed with his former
spouse, Lauren Trevino (Ms. Trevino). The issue for decision is
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