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petitioner’s claim for relief as an innocent spouse is somewhat
more complicated. In this case, respondent specifically reviewed
petitioner’s request for relief and granted $33,378 of the
$45,617 in relief requested by petitioner. Petitioner asks this
Court to review respondent’s failure to grant relief with respect
to the $12,239 balance.
With respect to petitioner’s separate request for innocent
spouse relief under section 6015, petitioner failed to make in
her original and amended petitions to this Court a specific claim
for relief from that determination. In that regard petitioner
received two separate notifications from respondent, one advising
that respondent would proceed with collection and the other
granting in part and denying in part petitioner’s request for
relief under section 6015. In the original petition, petitioner
generally requested review of respondent’s determination without
identifying which of the two determinations was in dispute. In
an amended petition, however, petitioner specifically limited her
request to review of the section 6330 notice to proceed with
collection.
Under section 6330(c)(2), however, petitioner is entitled to
raise certain issues, including spousal defenses. Consideration
of spousal defenses thus was anticipated in the context of a
section 6330 hearing. Therefore, our review will include
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Last modified: May 25, 2011