T.C. Memo. 2004-74
UNITED STATES TAX COURT
DONNA M. KEITZ, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2859-02. Filed March 18, 2004.
Donna M. Keitz, pro se.
Richard A. Stone, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DEAN, Special Trial Judge: This is a case arising under
section 6015.1 Unless otherwise indicated, section references
are to the Internal Revenue Code. Respondent determined
1 Sec. 6015 was enacted as part of the Internal Revenue
Service Restructuring and Reform Act of 1998, Pub. L. 105-206,
sec. 3201(a), 112 Stat. 734, and is effective for any liability
for tax arising after July 22, 1998, and any liability for tax
arising on or before July 22, 1998, but remaining unpaid as of
July 22, 1998.
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