- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011