Pamela J. Ellison - Page 12

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          solely attributable to the nonrequesting spouse, and (3) the                
          requesting spouse had knowledge or reason to know.  Accordingly,            
          Ms. Halbert concluded it was not inequitable to hold petitioner             
          liable.                                                                     
               On August 21, 2001, respondent mailed petitioner a                     
          preliminary determination with respect to petitioner’s request              
          for relief from joint and several liability for 1982 through                
          1986.  Respondent determined that petitioner was not entitled to            
          relief pursuant to section 6015(b), (c), or (f).                            
               On September 14, 2001, petitioner mailed respondent, among             
          other things, a statement of disagreement with respondent’s                 
          preliminary determination.                                                  
               Appeals Officer Bonnie Boak was assigned to review                     
          petitioner’s case.  Ms. Boak had no prior involvement with Hoyt             
          partnerships cases.                                                         
               On January 9, 2002, Ms. Boak mailed petitioner’s counsel a             
          letter that proposed arranging an Appeals conference.  That same            
          date, Ms. Boak mailed Mr. Ellison’s counsel (who also is                    
          petitioner’s counsel) a letter to notify Mr. Ellison of                     
          petitioner’s request for relief from joint and several liability            
          and offering Mr. Ellison the opportunity to submit any additional           
          information or to meet with Ms. Boak regarding petitioner’s                 
          claim.                                                                      








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