T.C. Memo. 2003-336
UNITED STATES TAX COURT
LOUISE SIRIANNI, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12866-02. Filed December 8, 2003.
Louise Sirianni, pro se.
Donna F. Herbert, for respondent.
MEMORANDUM OPINION
GERBER, Judge: Respondent moved for partial summary
judgment on the question of whether this Court has jurisdiction
to decide petitioner’s claim for relief under section 6015.1
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the period under
consideration, and all Rule references are to the Tax Court Rules
of Practice and Procedure.
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