Theresa E. Bartman, f.k.a. Theresa Albrecht - Page 1

                                 T.C. Memo. 2004-93                                   

                               UNITED STATES TAX COURT                                

             THERESA E. BARTMAN, f.k.a. THERESA ALBRECHT, Petitioner v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8139-02.              Filed April 6, 2004.                  

               Jack B. Schiffman, for petitioner.                                     
               Jonae A. Harrison, for respondent.                                     

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               FOLEY, Judge:  By Final Notice of Determination dated                  
          January 29, 2002, respondent determined that petitioner was not             
          entitled to relief from joint and several income tax liability              
          relating to 1994, 1995, or 1996.  After the petition was filed,             
          respondent granted petitioner relief from joint and several                 

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