T.C. Memo. 2007-326                                  
                               UNITED STATES TAX COURT                                
                           SUSAN KAY DOWELL, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 22650-05.             Filed October 30, 2007.               
               Susan Kay Dowell, pro se.                                              
               Steven W. LaBounty, for respondent.                                    
                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               FOLEY, Judge:  The issue for decision is whether petitioner,           
          pursuant to section 6015,1 is entitled to innocent spouse relief            
          with respect to her 2000 and 2001 Federal income tax liabilities.           
               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code of 1986, as amended.                              
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Last modified: November 10, 2007