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STROUD v. COMMISSIONER

Docket No. 1116-05.

92 T.C.M. 167 (2006)

T.C. Memo. 2006-175

Diana Stroud, Petitioner, and Thomas M. Stroud, Intervenor, v. Commissioner.

United States Tax Court.

August 22, 2006.

Attorney(s) appearing for the Case

Cruz Saavedra, for petitioner.

Thomas M. Stroud, pro se.

Michael R. Skutley, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

The issues for decision are whether this Court has jurisdiction pursuant to section 6015(e),1 to decide whether Diana Stroud (petitioner) is entitled to relief from joint Federal income tax liabilities relating to 1994 and 1996, and if so, whether respondent abused his discretion in denying petitioner a refund relating to 1994 and 1996.

FINDINGS OF FACT

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