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Year Refund Claimed and Due
1995 $6,044
1996 839
1997 384
1998 924
1999 637
On October 31, 1994, the Doyles submitted an offer in
compromise of their outstanding tax liabilities. Respondent did
not accept the offer in compromise.
On September 5, 2000, respondent issued to petitioner his
final Notice of Intent To Levy and Notice of Your Right To a
Hearing. On October 2, 2000, petitioner sent to respondent Form
8857, Request for Innocent Spouse Relief, and Form 12153, Request
for Collection Due Process Hearing, with respect to the
aforementioned tax liabilities. On January 23, February 20, and
May 8, 2001, hearings were held with the IRS Appeals Office to
determine the appropriateness of the proposed levy action. On
June 22, 2001, respondent issued a notice of determination
sustaining the proposed levy action. Respondent determined that
the tax liabilities were not discharged in the bankruptcy case,
and that petitioner did not qualify for relief from joint and
several liability under section 6015.
Petitioner’s Background Information
Petitioner has a high school education. From 1962 until
1983, petitioner was a homemaker and stay-at-home mother. During
the years at issue, petitioner had no business experience and no
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