- 10 - 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 1994Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011