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respondent’s determination to partially grant and deny section
6015 relief to petitioner.
Petitioner engaged in an extensive dialog with two different
Appeals officers, and she received consideration of all issues
raised, even though some were not as a matter of right under
section 6330(b). In addition to the assignment of one Appeals
officer to provide a section 6330 hearing, respondent assigned a
second Appeals officer to consider petitioner’s claim for relief
under section 6015. With respect to a section 6330 hearing, one
Appeals officer granted some relief with respect to the
underlying merits, even though petitioner was not entitled to
question the underlying merits under section 6330. With respect
to petitioner’s claim for section 6015 relief, she was afforded
$33,378 of the $45,617 in relief she requested. Petitioner asks
this Court to review respondent’s failure to grant relief with
respect to the $12,239 balance, but she has provided no evidence
or specific argument upon which we could hold that she is
entitled to such relief. She received a substantial amount of
relief from the outstanding 1994 income tax liability
(approximately 75 percent of the relief she requested).
Petitioner was also offered a collection alternative in the
form of installment payments, which she declined. Petitioner
claims that respondent has abused his discretion because he did
not consider additional questions as to the merits of the 1994
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Last modified: May 25, 2011