Margaret A. Durham - Page 1

                                 T.C. Memo. 2004-184                                  

                               UNITED STATES TAX COURT                                

                          MARGARET A. DURHAM, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10581-02.             Filed August 16, 2004.                

               Margaret A. Durham, pro se.                                            
               Edwina L. Jones, for respondent.                                       

                                 MEMORANDUM OPINION                                   

               PANUTHOS, Chief Special Trial Judge:  Respondent determined            
          that petitioner is not entitled to relief from joint and several            
          liability under section 6015 for the 1993 taxable year.1  The               
          issues for decision are:  (1) Whether petitioner is entitled to             

               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code, as amended, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure.                       

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