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letter to Mr. Mellen). That letter stated in pertinent part:
This is to inform you that Carolyn Mellen, who filed a
joint return with you for the tax year(s) shown above,
has requested relief from joint and several liability
under section 6015 * * *
If we grant the requested relief, you alone will be
solely liable for all or a portion of the tax liabil-
ity. That is, the IRS may only collect the balance due
from you. To insure the proper determination of who
pays the balance owed, you may want to participate in
the IRS proceedings by providing any of the following
information by October 15, 1999.
1. Whether Carolyn Mellen knew or had rea-
sons to know of the audit adjustments
and/or the balance due on the income tax
return(s) for the above tax period(s)
when he/she signed the return(s).
2. The current marital status between you
and Carolyn Mellen * * *
3. Whether Carolyn Mellen significantly
benefited from the unpaid liability.
4. Why it would be fair or unfair to hold
Carolyn Mellen liable for the tax lia-
bility.
Please provide specific details and appropriate docu-
mentation that support your information. * * *
Mr. Mellen did not respond to the foregoing letter.9
On October 29, 1999, respondent’s Joint Compliance Branch
sent petitioner another letter (respondent’s October 29, 1999
letter). That letter stated in pertinent part:
9Although Mr. Mellen did not respond to respondent’s Septem-
ber 10, 1999 letter to Mr. Mellen, in a letter dated Dec. 19,
1999, entitled “TRANSFER TO APPEALS REQUEST”, Mr. Mellen re-
quested that the examination of the 1994 joint return be trans-
ferred to an IRS Appeals officer (Appeals officer).
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