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6015(c), but that relief under other provisions would be denied
in full. In the letter, Mr. Zukle stated that he believed that
no additional payments would be due and, that to the best of his
knowledge, after the recommended relief was granted, petitioner
would be entitled to refunds for 1986 and 1987.
On June 20, 2001, a Form 2848, Power of Attorney and
Declaration of Representative, was signed by petitioner and his
current counsel, John R. McCabe (Mr. McCabe). Mr. McCabe was
retained to assist petitioner in his claim for relief from joint
and several liability. On July 9, 2001, Mr. McCabe sent a letter
to Mr. Zukle regarding petitioner’s entitlement to relief from
joint and several liability. The letter stated that an IRS
employee reviewing petitioner’s claim had referenced section
6015(c) and checked a form stating that there would be no refund
of the disputed debt. In another letter to Mr. Zukle, dated July
23, 2001, Mr. McCabe stated that he had recently discussed
petitioner’s claim for relief with an “Innocent Spouse
Coordinator” and had been told that there is no refund provision
when a claim is approved under section 6015(c).
By letter to petitioner dated July 25, 2001, respondent
accepted the offer in compromise of $6,000, subject to the
conditions and provisions stated on the Form 656. The letter
listed petitioner’s total account balance, as of April 30, 2001,
for the years 1986, 1987, and 1993 through 1999 as $185,962.
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