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HOPKINS v. COMMISSIONER

Docket No. 363-01.

120 T.C. 451 (2003)

120 T.C. No. 17

MARIANNE HOPKINS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 30, 2003.

Attorney(s) appearing for the Case

Sandra G. Scott, for petitioner.

Thomas M. Rohall, for respondent.

RUWE, Judge:

The issue for decision is whether a closing agreement entered into under section 71211 precludes the assertion of a claim for relief from joint and several liability under section 6015 where petitioner signed the closing agreement before the effective date of section 6015. We hold that it does not.

FINDINGS OF FACT

Some of the facts have been stipulated and are so found. The stipulation of facts and...

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