T.C. Memo. 2006-199
UNITED STATES TAX COURT
KATHLEEN SULLIVAN ALIOTO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14356-03. Filed September 18, 2006.
Karen L. Hawkins, for petitioner.
Michael E. Melone, Andrew R. Moore, and Davis G. Yee, for
respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: Respondent determined that petitioner did
not qualify for relief from joint and several liability for 1995
and 1996. The issue for decision is whether we have jurisdiction
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Last modified: May 25, 2011