Lisa Marie Pierce - Page 7

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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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