Cynthia J. Hall - Page 4

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               On September 28, 2001, respondent received petitioner’s                
          request for relief.                                                         
               On January 30, 2002, in a final notice of determination,               
          respondent determined that petitioner was not entitled to relief            
          for 1995 pursuant to section 6015 because she submitted the                 
          request for relief more than 2 years after respondent’s first               
          collection activity against her.                                            
               On April 16, 2002, petitioner, while residing in Soldotna,             
          Alaska, filed a letter which the Court treated as an imperfect              
          petition for determination of relief from joint and several                 
          liability on a joint return.  That same day, the Court ordered              
          petitioner to file, on or before May 14, 2002, a proper amended             
          petition for determination of relief from joint and several                 
          liability on a joint return.                                                
               On May 21, 2002, petitioner filed an amended petition for              
          determination of relief from joint and several liability on a               
          joint return seeking review of respondent’s determination to deny           
          equitable relief.                                                           
               On April 29, 2003, respondent filed a motion for summary               
          judgment.                                                                   
               On April 30, 2003, the Court ordered petitioner to file a              
          response to respondent’s motion for summary judgment on or before           
          May 14, 2003, and calendared the motion for summary judgment for            
          hearing at the Court’s Anchorage, Alaska, trial session.                    






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