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solely attributable to the nonrequesting spouse, and (3) the
requesting spouse had knowledge or reason to know. Accordingly,
Ms. Halbert concluded it was not inequitable to hold petitioner
liable.
On August 21, 2001, respondent mailed petitioner a
preliminary determination with respect to petitioner’s request
for relief from joint and several liability for 1982 through
1986. Respondent determined that petitioner was not entitled to
relief pursuant to section 6015(b), (c), or (f).
On September 14, 2001, petitioner mailed respondent, among
other things, a statement of disagreement with respondent’s
preliminary determination.
Appeals Officer Bonnie Boak was assigned to review
petitioner’s case. Ms. Boak had no prior involvement with Hoyt
partnerships cases.
On January 9, 2002, Ms. Boak mailed petitioner’s counsel a
letter that proposed arranging an Appeals conference. That same
date, Ms. Boak mailed Mr. Ellison’s counsel (who also is
petitioner’s counsel) a letter to notify Mr. Ellison of
petitioner’s request for relief from joint and several liability
and offering Mr. Ellison the opportunity to submit any additional
information or to meet with Ms. Boak regarding petitioner’s
claim.
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