T.C. Memo. 2003-301
UNITED STATES TAX COURT
RUTHE G. OHRMAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5667-02. Filed October 29, 2003.
Steven B. Hval, for petitioner.
Nhi T. Luu-Sanders, 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 1999
with respect to a joint return filed with Steven F. Ohrman
(Mr. Ohrman). The issues for decision are: (1) Whether
petitioner is eligible for relief from joint and several
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