MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined a deficiency of $99,672 in petitioner's Federal income tax for 1998, which was subsequently reduced by respondent's concession to $63,344. After concessions, the issue for decision is whether petitioner is entitled to relief from joint and several liability under section 6015(b) or (c).
Unless otherwise indicated, all section references are to the Internal Revenue Code in...
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