Ingrid Capehart - Page 18

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          Petitioner’s Claim for Section 6015 Relief                                  
               On or about August 29, 2000, petitioner filed Form 8857,               
          Request for Innocent Spouse Relief (And Separation of Liability             
          and Equitable Relief), on which she requested relief pursuant to            
          section 6015(b) and (f) for 1980 through 1997.8                             
               On August 24, 2001, respondent sent petitioner a preliminary           
          determination denying petitioner’s request for relief under                 
          section 6015(b), (c), and (f) for 1980 through 1986.  Respondent            
          denied relief on the basis that:  (1) Petitioner had actual                 
          knowledge or reason to know of the item giving rise to the                  
          understatement; (2) petitioner did not show that 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 to the             
          IRS Appeals Division.                                                       
               On December 4, 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              

               8On Nov. 14, 2000, respondent sent petitioner a letter that            
          indicated petitioner’s request for relief with respect to the               
          1987 through 1997 taxable years was premature.                              





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