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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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