T.C. Memo. 2004-212
UNITED STATES TAX COURT
DELLA H. KNORR, Petitioner, AND DUANE J. KNORR, Intervenor v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7440-01. Filed September 21, 2004.
Michael R. N. McDonnell, for petitioner.
Duane J. Knorr, pro se.
Lorianne D. Masano, 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 1990,
1991, 1992, 1993, 1994, and 1995 with respect to joint income tax
returns that she filed with her former husband. The issue for
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