MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge:
Petitioner timely filed a petition seeking review of respondent's determination denying her relief from joint and several liability for the years 1994, 1995, and 1999 under section 6015(f).
We review respondent's determination for abuse of discretion, and for the reasons explained herein we find respondent's determination was in error.
FINDINGS OF FACT
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