Marianne Hopkins - Page 1

                                   120 T.C. No. 17                                    

                               UNITED STATES TAX COURT                                

                           MARIANNE HOPKINS, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 363-01.                Filed June 30, 2003.                 

                    P filed a request for relief under sec. 6015,                     
               I.R.C., with respect to her joint and several tax                      
               liabilities for 1982 and 1983.  P and H reported loss                  
               deductions from a partnership on their returns for                     
               those years.  In 1988, P and H signed a closing                        
               agreement under sec. 7121, I.R.C., in which they agreed                
               to adjustments with respect to the partnership                         
               deductions.  The adjustments to the partnership                        
               deductions resulted in tax deficiencies for 1982 and                   
               1983, which R assessed.  The tax liabilities for those                 
               years were the subject of a prior bankruptcy case                      
               involving P and H and the Government.  In that case, P                 
               raised a claim for relief from joint and several                       
               liability under former sec. 6013(e), I.R.C.  The                       
               bankruptcy court entered judgment holding that the                     
               closing agreement precluded P from asserting her claim                 
               for relief under sec. 6013(e), I.R.C.  A Federal                       
               District Court and the Court of Appeals for the Ninth                  
               Circuit affirmed the bankruptcy court’s judgment.  See                 
               Hopkins v. United States (In re Hopkins), 146 F.3d 729                 
               (9th Cir. 1998).  R argues that the closing agreement P                

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