FOLEY, Judge:
By Final Notice of Determination dated January 29, 2002, respondent determined that petitioner was not entitled to relief from joint and several income tax liability relating to 1994, 1995, or 1996. After the petition was filed, respondent granted petitioner relief from joint and several liability relating to the years in issue. The sole issue for decision is whether petitioner is entitled to a refund of her 1995 overpayment. The parties submitted this...
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