Maria Rivera - Page 1

                                 T.C. Memo. 2005-33                                   

                               UNITED STATES TAX COURT                                

                             MARIA RIVERA, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 7394-03.             Filed February 24, 2005.               

               Maria Rivera, pro se.                                                  
               John W. Strate, for respondent.                                        

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               VASQUEZ, Judge:  Respondent determined that petitioner                 
          qualifies for relief from joint and several liability pursuant to           
          section 6015(c) for 1988 and 1989.1  After concessions, the issue           

               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      

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