Joseph Dutton - Page 5

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          Balances of $37,162 and $84,124 were shown for 1986 and 1987,               
          respectively.  The letter was signed on respondent’s behalf by              
          Mark Jaramillo (Mr. Jaramillo), Steve Turner, and K. Vega.  Mr.             
          Jaramillo also sent a copy of the acceptance letter to Mr.                  
          Phillips on July 25, 2001.  Petitioner has completed the payment            
          plan for his offer in compromise, and copies of TXMODA                      
          transcripts3 for the year 1986 and 1987 show a balance due of               
          zero.                                                                       
               By notice of determination dated August 12, 2002, respondent           
          determined that petitioner was not entitled to relief from joint            
          and several liability under section 6013(e) and section 6015(b),            
          (c), and (f) for the years 1986 and 1987.4  The notice listed Al            
          Petroff as a contact person and was signed by Jon S. Leo, Appeals           
          Team Manager.  Petitioner filed a petition under section                    
          6015(e)(1) seeking a review of respondent’s determination for the           
          years 1986 and 1987.                                                        



               3A TXMODA transcript contains current account information              
          obtained from the Commissioner’s master file.  “TXMODA” is the              
          command code that is entered in the Commissioner’s integrated               
          data retrieval system (IDRS) to obtain the transcript.  IDRS is             
          essentially the interface between the Commissioner’s employees              
          and various computer systems.  Tornichio v. Commissioner, T.C.              
          Memo. 2002-291 n.5.                                                         
               4The evidence in the record does not explain why the notice            
          of determination addressed the years 1986 and 1987 when                     
          petitioner’s request for relief was for the years 1984, 1985, and           
          1986.  In his petition, petitioner does not seek relief for the             
          year 1984 or 1985.                                                          




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