T.C. Memo. 2004-268
UNITED STATES TAX COURT
INGRID CAPEHART, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3425-03. Filed November 22, 2004.
Terri Ann Merriam, Jennifer A. Gellner, and Wendy S.
Pearson, for petitioner.
Robert V. Boeshaar and Julie L. Payne, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge: This case arises from a request for relief
under section 60151 with respect to petitioner’s 1980 through
1986 taxable years. Respondent determined that petitioner was
1All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
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