Lisa Marie Pierce - Page 6

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          petitioner's payroll office informed her of a notice of tax levy            
          it received from respondent.  This was the first petitioner                 
          learned of the outstanding unpaid tax liability for 1994.                   
          Petitioner filed her 1995 tax return and reported an overpayment            
          of $336.82, which the Internal Revenue Service (IRS) applied to             
          the unpaid balance for the 1994 tax year.  The IRS also applied             
          an overpayment of $2,661.12 from Mr. Pierce's 1995 tax return to            
          the unpaid balance from 1994.                                               
               When petitioner's payroll office advised her of the levy               
          notice, she also became aware that Mr. Pierce never filed their             
          joint returns for 1992 and 1993.  On April 29, 1996, petitioner             
          filed her Federal income tax returns for 1992 and 1993 as married           
          filing separate, claiming overpayments of $430.03 and $316.53               
          respectively.  Petitioner filed her 1998 tax return claiming an             
          overpayment of $464.22, which the IRS applied to the unpaid                 
          balance for 1994.                                                           
               On March 31, 2000 a "Final Notice – Notice of Intent to Levy           
          and Notice of Your Right to a Hearing" letter was sent to both              
          petitioner and Mr. Pierce.  On April 7, 2000, petitioner timely             
          submitted a request for a hearing.  Petitioner submitted, with              
          the request for the hearing, a Form 8857, Request for Innocent              
          Spouse Relief, and an attached explanatory letter.                          
               On October 31, 2000, the Examination Division sent                     
          petitioner a letter requesting more information and documentation           






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