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equitable relief under section 6015(f). Although petitioner knew
prior to the November 14, 2000 hearing that the Appeals officer
wanted to discuss with her the reasons why she believed that she
was entitled to equitable relief under section 6015(f), peti-
tioner did not bring with her to that hearing any documentation
supporting her position that she was entitled to such relief.
The Appeals officer considered all of the information that
petitioner shared with him during the November 14, 2000 hearing.
As reflected in respondent’s administrative record pertaining to
petitioner (respondent’s administrative record) which the Appeals
officer created and/or on which he relied in arriving at his
determination that petitioner was not entitled to equitable
relief under section 6015(f), petitioner informed the Appeals
officer at that hearing that as of the date of that hearing:
(1) She was “still married to her husband, Craig Mellen, with
whom she filed the joint 1995 Form 1040”; (2) she “signed the
1995 Form 1040 because her husband told her that that is what the
accountant wanted” but had “never met the accountant”; (3) she
“prepared her own income tax returns when she filed income tax
returns separately from her husband” and “did not use a paid
return preparer for completing or filing these income tax re-
turns”; (4) she “has been working for eleven years”; (5) she “and
her husband support the household”; (6) “her husband pays the
mortgage payments to their home with his disability income”;
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