Debra Anne Banderas - Page 1

                                 T.C. Memo. 2006-228                                  

                               UNITED STATES TAX COURT                                

                         DEBRA ANNE BANDERAS, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 7733-05.              Filed October 24, 2006.               

                    Held:  Petition for determination of relief from                  
               joint and several liability under sec. 6015(f), I.R.C.,                
               dismissed for lack of jurisdiction.  Billings v.                       
               Commissioner, 127 T.C. 7 (2006), followed.                             

               James R. Monroe, for petitioner.                                       
               Miriam C. Dillard, for respondent.                                     

                                 MEMORANDUM OPINION                                   

               WHERRY, Judge:  This case arises from a petition for                   
          judicial review filed in response to a determination concerning             

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