- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011