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the erroneous items were attributable to her spouse; (3)
petitioner did not demonstrate that it would be inequitable to
hold her liable for the deficiency attributable to the
understatement; and (4) petitioner did not meet the marital
status requirements of section 6015(c). On September 17, 2001,
petitioner timely submitted a written appeal of respondent’s
determination.
On September 26, 2002, respondent issued a notice of
determination in which he concluded that petitioner did not
qualify for relief from joint and several liability under section
6015(b), (c), or (f). With respect to his determination under
section 6015(b), respondent stated that “You failed to meet all
the requirements of IRC section 6015(b); therefore, you do not
qualify for relief under the law.” With respect to his
determination under section 6015(f), respondent stated that “You
are not eligible for relief under the law since the majority of
the factors weighs against relief.”
On December 23, 2002, petitioner timely filed a petition
with this Court pursuant to section 6015(e) seeking review of
respondent’s determination with respect to section 6015(b) and
(f) for petitioner’s 1982-86 taxable years.9
9We consider petitioner’s request for relief under sec.
6015(f) even though she originally requested relief on Form 8857,
Request for Innocent Spouse Relief (And Separation of Liability
and Equitable Relief), under sec. 6015(b) only. Respondent
(continued...)
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