Julie C. Nichols, n.k.a. Julie C. Amrein - Page 1

                                 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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