United States Tax Court February 11, 2004, No. 17802-02 (Dutton v. Comm'r)

lead-opinion

OPINION

Goeke, Judge:

This matter is before the Court on the issue of whether petitioner is barred from seeking relief from joint and several liability under former section 6013(e)1 and section 6015 for the years 1986 and 1987 because he entered into an offer in compromise with respondent for those years.