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* * * * * * *
*Was a letter sent asking for specific info? If so, I
did not receive it.
1The following handwritten notation appeared in
the margin of petitioner’s statement of disagreement
near the telephone number that petitioner provided
therein: “Disconnected called 11/9/00". The record
does not disclose who made that notation. The tele-
phone number at which petitioner indicated “Any further
inquiries can be made by calling” was petitioner’s
office telephone number at Questar.
On February 14, 2000, respondent sent petitioner and Mr.
Mellen a notice of intent to levy with respect to taxable year
1995. On March 24, 2000, in response to that notice, petitioner
sent respondent a letter. That letter stated in pertinent part:
I have filed for Innocent Spouse Relief for this par-
ticular year and was told that since a decision is
still pending and is in Appeals Court [sic], no action
should be taken against me or my property.
My husband was ill advised as to how to file taxes for
the year 1995. He should not have filed a joint re-
turn, and I would not have to appeal this matter. I
have a W-2 that specifically shows what money I earned
for 1995. I in no way had anything to do with his
capital gains.
On November 14, 2000, an Appeals officer met with petitioner
(November 14, 2000 hearing) for at least 30 minutes and no more
than one hour. The purpose of that hearing was to discuss
petitioner’s request for equitable relief under section 6015(f).
At the November 14, 2000 hearing, the Appeals officer questioned
petitioner, and petitioner had the opportunity to present infor-
mation including documentation, with respect to her claim for
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