- 2 - sec. 6015, I.R.C. Internal Revenue Service Restructuring and Reform Act of 1998 (RRA 1998), sec. 3501(b), Pub. L. 105-206, 112 Stat. 770. Held, further, It is inequitable and an abuse of discretion for R to apply the 2-year limitation period of Rev. Proc. 2000-15, sec. 5, 2000-1 C.B. 447, 449, because of R’s failure to send the notice required by RRA 1998 sec. 3501(b). Natalie W. McGee, pro se. Marshall R. Jones, for respondent. OPINION GOEKE, Judge: The sole matter before the Court is whether it was an abuse of discretion for respondent to deny petitioner’s request for equitable relief from joint liability based on section 6015(f)1 solely because petitioner made her request more than 2 years after respondent’s first collection activity. Petitioner challenges the application of the 2-year limit on section 6015(f) requests imposed by Rev. Proc. 2000-15, sec. 5, 2000-1 C.B. 447, 449, when inadequate notice of collection activity was sent to her, and, as a result, she did not become aware of her section 6015 rights until after the 2-year period expired. 1Unless otherwise indicated, all section references are to the Internal Revenue Code currently in effect.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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