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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