Louise Demirjian - Page 1

                                 T.C. Memo. 2004-22                                   


                               UNITED STATES TAX COURT                                


                           LOUISE DEMIRJIAN, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8836-02.             Filed January 30, 2004.                


               Chris Pappas, for petitioner.                                          
               Gerard Mackey, 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 any             
          portion of the unpaid interest resulting from an understatement             
          of tax on a joint return filed with her former husband for 1989.            
          The issues for decision are:  (1) Whether petitioner is eligible            





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