T.C. Memo. 2006-2
UNITED STATES TAX COURT
PHYLLIS J. MERENDINO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8265-04. Filed January 3, 2006.
C. Page Hamrick III, for petitioner.
Stephen J. Neubeck, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge: Petitioner challenges respondent’s April 2004
determination that she is not entitled to equitable relief from
joint and several liability under section 6015(f)1 for
1All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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