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We have determined that:
[X] You are not entitled to relief from the under-
statement of tax liability as an innocent spouse.
[X] Explanation for why relief was not granted:
You have not provided any information to show what the
exam issues were and that you did not know or have any
reason to know of the basis for the understatement of
tax.
If you want to appeal our decision, you must provide a
statement why you disagree with our decision. We have
provided space at the end of this letter for you to
provide your statement of disagreement. If that space
is not adequate, you may attach a separate statement
with a copy of this letter. * * *
On November 5, 1999, petitioner returned to respondent
respondent’s October 29, 1999 letter and indicated in the space
provided in that letter for petitioner’s statement of disagree-
ment (petitioner’s statement of disagreement) that she disagreed
with respondent’s determination that she was not entitled to
relief under section 6015. In support of her disagreement,
petitioner asserted in pertinent part:
I, Carolyn Mellen, disagree with the above IRS decision
because: As I notified you previously, I have NO
knowledge of my husband’s stock purchases or capital
gains for the 1995. [sic] I can provide a copy of my
W-2 form for that year, which I’m sure you probably
already have. That was the total amount of my earn-
ings. I had no benefit from any stock or capital
gains. I believe the audit was a result of stock &
capital gains concerns and not my measly income. I do
not know what papers I was to provide for this investi-
gation.* To my knowledge, I submitted everything I was
asked to provide. I’m sure, if necessary, I can get a
tax attorney to review my situation.
Any further inquiries can be made by calling me at 325-
5774 (801).[1]
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