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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 &
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Last modified: May 25, 2011