- 17 - petitioner and her representatives originally come forward at the administrative Appeals conference, offered in May 1992, with the relevant facts to demonstrate that she had not filed joint returns for the years in issue, we have every reason to believe that her case could have been resolved without the need for this litigation.16 We hold that petitioner did not exhaust her administrative remedies, since she failed to request an Appeals office conference which was offered by respondent in the 30-day letter. Kenlin Indus., Inc. v. United States, 927 F.2d 782, 788 (4th Cir. 1991); see also Minahan v. Commissioner, 88 T.C. 492, 508 (1987). Therefore, petitioner is not entitled to an award of reasonable litigation costs. As a result of our disposition, we express no opinion as to whether any of the remaining requirements of section 7430 have been satisfied. An appropriate order will be issued. 16Even an Appeals conference regarding petitioner's initial position that she was an innocent spouse would have had to explore the issues of whether the 1985, 1986, and 1987 returns were joint returns, petitioner's involvement in their preparation, and her involvement in and knowledge of the underlying transactions.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
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