- 6 - Miller’s claim for ‘innocent spouse’ relief” included peti- tioner’s claim that respondent erroneously granted relief from joint and several liability to Ms. Bacon with respect to the assessed 1990 tax deficiency and that he should have received notice of and an opportunity to contest Ms. Bacon’s application for such relief. The notice of determination contained the following summary of the determinations that were made by the Appeals Office with respect to the matters that were considered at petitioner’s Appeals Office hearing: Summary of Determination: The statutory and procedural notice requirements prior to levy were met by the Service. Therefore, levy is permissible. Further, under Mr. Miller’s circum- stances, the proposed levy balances the need to collect the revenue with the intrusiveness of the proposed action. No collection alternatives were offered because Mr. Miller challenged the liability. Mr. Miller’s claim for innocent spouse relief was considered and found to be meritless. In the amended petition for lien or levy action under section 6320(c) or 6330(d), petitioner alleged the following errors of the Appeals Office in making the determinations summa- rized in the notice of determination: 5. Alleged errors in determination: 1. Innocent spouse relief granted to my ex- wife without me being notified. 2. Ex-wife signed divorce decree acknowledg- ing her tax responsibilities for tax years ‘89 &Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011