Nita B. Leissner - Page 2

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               Donald R. Williams, for petitioner.                                    
               Audrey M. Morris, for respondent.                                      


                                 MEMORANDUM OPINION                                   

               NIMS, Judge:  Respondent determined that petitioner is not             
          entitled to relief from joint and several liability for tax under           
          section 6015(f) for 1986 and 1987.  Petitioner filed a petition             
          under section 6015(e)(1) seeking review of respondent’s                     
          determination.  The parties agree that petitioner would be                  
          eligible for relief under section 6015(f) if refund or credit of            
          a resulting overpayment were not statutorily barred.  The issue             
          for decision is therefore whether such refund or credit is                  
          available to petitioner for her taxable years 1986 and 1987.                
               Unless otherwise indicated, all section references are to              
          sections of the Internal Revenue Code in effect at all relevant             
          times, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     
               This case was submitted fully stipulated pursuant to Rule              
          122, and the facts are so found.  The stipulations of the                   
          parties, with accompanying exhibits, are incorporated herein by             
          this reference.                                                             
                                     Background                                       
               At the time the petition was filed in this case, petitioner            
          resided in Kerrville, Texas.                                                





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