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regarding her claim for relief from joint and several liability.
On November 13, 2000, petitioner sent additional information to
the Examination Division in support of her claim. On October 11,
2001, the Appeals Office sent petitioner a letter indicating the
suspension of her collection claim and outlining the findings of
her claim for relief from joint and several liability.
Respondent, therefore, denied petitioner's collection claim
because she was not entitled to relief from joint and several
liability. As a result, a notice of determination was issued
sustaining the issuance of the levy.
On November 2, 2001, respondent sent petitioner an
application for an Offer in Compromise as well as a request for
petitioner to submit a detailed current financial statement.
Petitioner only submitted a 1996 financial statement.
Petitioner failed to respond to the Offer in Compromise and did
not provide respondent with a current financial statement.
Respondent sent petitioner a Notice of Determination (NOD)
on April 8, 2002, which stated that respondent had followed all
procedures in the issuance of the notice of intent to levy and
that petitioner's collection appeal rights were not violated.
The NOD also determined that petitioner did not qualify for
relief from joint and several liability under the provisions of
section 6015(f). On May 10, 2002, petitioner timely filed with
the Court her petition for review of respondent's determination.
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Last modified: May 25, 2011