- 12 - 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011