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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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