T.C. Memo. 2004-84
UNITED STATES TAX COURT
ANDREA J. VUXTA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 102-03. Filed March 23, 2004.
Albert N. Peterlin, for petitioner.
Richard A. Stone, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PANUTHOS, Chief Special Trial 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 with respect to unpaid tax
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