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faced with the Commissioner’s reliance on the 2-year limitation
period when the Commissioner took an inconsistent position in
failing to provide the collection-related notice required by RRA
1998 sec. 3501(a). In this case, respondent’s treatment of the
offset as a collection action, coupled with his failure to send
petitioner notice of her section 6015 rights as required by RRA
1998 sec. 3501, resulted in petitioner’s failure to seek section
6015(f) relief within 2 years after the first collection action
because she did not know of her rights. The problem here is not
with the language of the revenue procedure per se, but that the
revenue procedure has been interpreted in this case in a fashion
inconsistent with respondent’s application of the public law, and
that interpretation causes a result that is inconsistent with the
statutory scheme.
It would be inequitable if respondent could prevent review
of a request for relief under section 6015(f) by failing to
inform petitioner of her right to relief in defiance of a
congressional mandate. Such a result would be contrary to the
very purpose of section 6015(f), which is to relieve inequitable
situations involving joint liabilities. Respondent’s
administrative interpretations are given little weight when
inconsistent with a statutory scheme. United States v. Vogel
Fertilizer Co., 455 U.S. 16, 26 (1982); FEC v. Democratic
Senatorial Campaign Comm., 454 U.S. 27, 30 (1981). Rev. Proc.
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