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On February 14, 2002, petitioner’s counsel mailed a letter
to Ms. Boak that supplemented the facts and legal arguments for
her consideration.
Ms. Boak provided petitioner with the opportunity to submit
any additional information for Ms. Boak to consider before
completing her review of petitioner’s case. Ms. Boak reviewed
and considered everything submitted to her by petitioner and her
attorneys. Ms. Boak spent approximately 10 to 20 hours on the
phone with petitioner’s attorneys discussing petitioner’s case.
On April 2, 2002, Ms. Boak wrote petitioner’s counsel a
5-page letter advising her (petitioner’s counsel) that she agreed
with the service center’s decision to deny section 6015 relief
and provided a detailed explanation supporting her conclusions
and responding to petitioner’s counsel’s legal arguments.
On or about April 8, 2002, after completing her review of
petitioner’s case (which included all materials contained in
respondent’s file and provided by petitioner and her counsel),
Ms. Boak prepared an Appeals Case Memorandum. Ms. Boak concluded
that petitioner was not entitled to relief from liability
pursuant to section 6015(b), (c), or (f) for 1982 through 1986.
Team Manager Leonard Bartold approved Ms. Boak’s Appeals Case
Memorandum.
On April 17, 2002, respondent mailed petitioner a notice of
determination that determined petitioner was not entitled to
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