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collection activity effective for requests for relief from joint
and several liability filed on or after July 18, 2002).
Pursuant to section 6402(a), respondent applied petitioner’s
1998 overpayment against her 1995 tax liability. Accordingly,
respondent engaged in a collection activity against petitioner.
Respondent’s first collection activity after July 22, 1998,
occurred on April 15, 1999. Petitioner submitted her request for
relief on September 10, 2001. Accordingly, petitioner made her
request for relief more than 2 years after respondent’s first
collection activity after July 22, 1998. Therefore, petitioner’s
request for relief was untimely, and she is not entitled to
relief pursuant to section 6015. See Campbell v. Commissioner,
supra at 292-293.
Petitioner claims that it is unfair to deny her relief
because she thought her divorce decree relieved her of the 1995
tax liability. While we sympathize with petitioner, her request
for relief was untimely.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011