Cynthia J. Hall - Page 6

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          collection activity effective for requests for relief from joint            
          and several liability filed on or after July 18, 2002).                     
               Pursuant to section 6402(a), respondent applied petitioner’s           
          1998 overpayment against her 1995 tax liability.  Accordingly,              
          respondent engaged in a collection activity against petitioner.             
               Respondent’s first collection activity after July 22, 1998,            
          occurred on April 15, 1999.  Petitioner submitted her request for           
          relief on September 10, 2001.  Accordingly, petitioner made her             
          request for relief more than 2 years after respondent’s first               
          collection activity after July 22, 1998.  Therefore, petitioner’s           
          request for relief was untimely, and she is not entitled to                 
          relief pursuant to section 6015.  See Campbell v. Commissioner,             
          supra at 292-293.                                                           
               Petitioner claims that it is unfair to deny her relief                 
          because she thought her divorce decree relieved her of the 1995             
          tax liability.  While we sympathize with petitioner, her request            
          for relief was untimely.                                                    
               To reflect the foregoing,                                              


                                                  An appropriate order and            
                                             decision will be entered.                











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