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or reason to know. Accordingly, Ms. Halbert concluded it was not
inequitable to hold petitioner liable.
On August 24, 2001, respondent mailed petitioner a
preliminary determination with respect to petitioner’s request
for relief from joint and several liability for 1980 through
1986. Respondent determined that petitioner was not entitled to
relief pursuant to section 6015(b), (c), or (f).
On November 27, 2001, respondent mailed petitioner a notice
of determination that determined petitioner was not entitled to
relief from liability pursuant to section 6015(b), (c), or (f)
for 1980 through 1986. That same day, respondent mailed Mr.
Bartak a letter notifying him that petitioner’s request for
relief from joint and several liability had been denied.
After the petition and answer in this case were filed,
petitioner’s section 6015 claim was forwarded to respondent’s
Appeals Office. Appeals Officer Gloria J. Flandez was assigned
to review petitioner’s case. Ms. Flandez reviewed and considered
the information submitted to her by petitioner and her attorneys.
On or about November 6, 2002, after completing her review of
petitioner’s case, Ms. Flandez prepared an Appeals Case
Memorandum. Ms. Flandez concluded that petitioner was not
entitled to relief from liability pursuant to section 6015(b),
(c), or (f) for 1982 through 1986. Appeals Team Manager Robert
M. Spooner approved Ms. Flandez’s Appeal Case Memorandum.
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