E. Carolyn Mellen - Page 14




                                                - 14 -                                                  
                      *       *       *       *       *       *       *                                 
                  *Was a letter sent asking for specific info?  If so, I                                
                  did not receive it.                                                                   

                        1The following handwritten notation appeared in                                 
                  the margin of petitioner’s statement of disagreement                                  
                  near the telephone number that petitioner provided                                    
                  therein:  “Disconnected called 11/9/00".  The record                                  
                  does not disclose who made that notation.  The tele-                                  
                  phone number at which petitioner indicated “Any further                               
                  inquiries can be made by calling” was petitioner’s                                    
                  office telephone number at Questar.                                                   
                  On February 14, 2000, respondent sent petitioner and Mr.                              
            Mellen a notice of intent to levy with respect to taxable year                              
            1995.  On March 24, 2000, in response to that notice, petitioner                            
            sent respondent a letter.  That letter stated in pertinent part:                            
                  I have filed for Innocent Spouse Relief for this par-                                 
                  ticular year and was told that since a decision is                                    
                  still pending and is in Appeals Court [sic], no action                                
                  should be taken against me or my property.                                            
                  My husband was ill advised as to how to file taxes for                                
                  the year 1995.  He should not have filed a joint re-                                  
                  turn, and I would not have to appeal this matter.  I                                  
                  have a W-2 that specifically shows what money I earned                                
                  for 1995.  I in no way had anything to do with his                                    
                  capital gains.                                                                        
                  On November 14, 2000, an Appeals officer met with petitioner                          
            (November 14, 2000 hearing) for at least 30 minutes and no more                             
            than one hour.  The purpose of that hearing was to discuss                                  
            petitioner’s request for equitable relief under section 6015(f).                            
            At the November 14, 2000 hearing, the Appeals officer questioned                            
            petitioner, and petitioner had the opportunity to present infor-                            
            mation including documentation, with respect to her claim for                               






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