T.C. Memo. 2004-181
UNITED STATES TAX COURT
ANNETTE L. MORELLO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2790-03. Filed August 5, 2004.
Annette L. Morello, pro se.
Robert F. Saal, 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 1992,
1993, 1994, and 1995 with respect to joint income tax returns
that she filed with her former husband. The issue for decision
is whether respondent abused respondent’s discretion in denying
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