MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge:
The petition in this case was filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. The sole issue for decision is whether respondent erroneously denied petitioner's request for relief from joint tax liability pursuant to section 6015(b) or (f).
FINDINGS OF FACT
Some of the facts have been stipulated...
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