Jeanne M. Trent - Page 8

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          unless the individual’s qualification for relief was not an issue           
          in the prior court proceeding and the individual did not                    
          participate meaningfully in the prior proceeding.  In Vetrano v.            
          Commissioner, supra at 278, the Court stated:                               
               an individual who participated meaningfully in a court                 
               proceeding is precluded from electing relief under                     
               section 6015(b) or (c) for the same taxable year after                 
               the decision of the court becomes final, whether or not                
               the individual’s qualification for relief under section                
               6015(b) or (c) was an issue in the prior proceeding.                   
               Petitioner filed a petition for redetermination of the 1994            
          liability with the Court.  She then met with the Appeals officer            
          to discuss her case.  She personally participated in the meetings           
          with the Appeals officer, and she conceded at trial that she                
          signed the decision document freely and voluntarily.                        
               Petitioner testified that she raised the issue of relief               
          from joint and several liability with the Appeals officer and               
          that the Appeals officer declined to consider the issue at that             
          time.  Relying on statements by the Appeals officer, petitioner             
          argues that section 6015 relief was not an issue in the first               
          proceeding.  She argues that her level of involvement in the                
          prior case was not “meaningful” for purposes of section                     
          6015(g)(2) because she was not represented by counsel, was not              
          involved in discussions of law or procedure, and was not                    
          knowledgeable about law or procedure.                                       
               The quality of advocacy and the actual knowledge of the                
          litigants are not special circumstances in determining whether a            

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