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section 6015(c) for all amounts owed as of July 22, 1998, but
that her request for refund was untimely.
By letter to respondent’s Appeals officer dated December 19,
1999, petitioner told respondent that she disagreed with
respondent’s conclusion because it meant she was not entitled to
a refund. On January 23, 2001, petitioner faxed copies of her
July 31, 1995, letter and Kohl’s October 3, 1995, letter to
respondent’s Appeals officer. By letter to respondent’s Appeals
officer dated March 1, 2001, petitioner said that she did not
understand why she was not entitled to a refund. By letter to
respondent’s Appeals officer dated March 16, 2001, petitioner
withdrew her claims under section 6015 for 1981 and 1982.
Respondent determined on July 20, 2001, that petitioner
(1) is entitled to relief under section 6015(c) in the amount of
tax owed as of July 22, 1998 ($5,219 for 1983 and $48 for 1984),
(2) is not entitled to equitable relief under section 6015(f) for
1983 and 1984, and (3) is not entitled to a refund for 1983 and
1984 because her request for a refund was not timely. Petitioner
timely filed a petition and an amended petition in which she
seeks review of respondent’s determination.
OPINION
A. Petitioner’s Contentions
Petitioner contends that it is inequitable to hold her
jointly liable for tax she paid before July 23, 1998, that is
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