T.C. Memo. 2004-61
UNITED STATES TAX COURT
JULIE C. NICHOLS, n.k.a. JULIE C. AMREIN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8227-02. Filed March 11, 2004.
Julie C. Nichols, pro se.
James A. Kutten, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined a deficiency of $99,672
in petitioner’s Federal income tax for 1998, which was
subsequently reduced by respondent’s concession to $63,344.
After concessions, the issue for decision is whether petitioner
is entitled to relief from joint and several liability under
section 6015(b) or (c).
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