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Rept. 105-599, at 251 (1998), 1998-3 C.B. 747, 1005. In
addition, RRA 1998 sec. 3501 and the legislative history reflect
Congress’s view that knowledge of the relief provisions by
married taxpayers was important to the effective application of
section 6015. Section 6015 added new options for taxpayers
seeking relief from joint liability. See King v. Commissioner,
115 T.C. 118, 120 (2000); Corson v. Commissioner, 114 T.C. 354,
359 (2000). The notice of the offset in this case (the
“accounting adjustment” notice) did not inform petitioner of her
section 6015 rights, and, as a result, petitioner was unaware of
her rights to relief under section 6015 until she hired counsel
in late 2001.
The incongruity of respondent’s position is untenable. The
offset was a collection action. Campbell v. Commissioner, 121
T.C. 290, 292 (2003). Accordingly, the notice of the offset was
a collection-related notice and should have included the
information required by RRA 1998 sec. 3501(b).
Respondent asserts that petitioner’s claim is nonetheless
barred by the 2-year limitation period reflected in Rev. Proc.
2000-15, sec. 5. Rev. Proc. 2000-15, supra, has been cited and
referenced by this Court in determining whether the Commissioner
abused his discretion in determinations regarding section
6015(f). Campbell v. Commissioner, supra at 292; Hall v.
Commissioner, T.C. Memo. 2004-170. We have not previously been
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