T.C. Memo. 2004-176
UNITED STATES TAX COURT
PHILIP CULLEN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4741-03. Filed July 28, 2004.
Philip Cullen, pro se.
Horace Crump, for respondent
MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, 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 tax return filed with Mary Cullen
(Ms. Cullen). The issues for decision are: (1) Whether
petitioner is eligible for relief from joint and several
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