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submitted a Form 12153, in which she disagreed with the proposed
collection action because of the “Innocent Spouse Rule”. Ms.
Pless also submitted a Form 8857, Request for Innocent Spouse
Relief. In the Form 8857, Ms. Pless requested equitable relief;
i.e., relief from joint and several liability under section
6015(f) with respect to the underpayment of the tax shown on the
1998 return.
On June 13, 2001, an Appeals officer for the IRS sent to
petitioners a letter referring to the claims for relief that had
been submitted by them. The letter stated:
Your request for a Due Process Hearing will be
scheduled after the innocent spouse claim has been
worked. The Due Process Hearing may be in person or
over the phone. Please let me know which you prefer
when you are contacted to schedule your Due Process
Hearing.
* * * * * * *
If you plan to propose collection alternatives, certain
financial information is needed in order to determine
the merits of any collection alternative proposal you
make. In this regard, if you plan to propose
collection alternatives, please complete the enclosed
Form 433-A and Form 433-B (if applicable) and return
them to me as soon as possible.
Since interest continues to accrue while your case is
being considered, you may wish to pay as much as you
can as soon as you can. If you have questions or
concerns, please contact me at the above address, fax
or telephone number.
Also on June 13, 2001, the Appeals officer sent to an “Innocent
Spouse Coordinator” Ms. Pless’s Form 8857, noting: “Ms. Pless
did not provide any explanation as to why she feels she qualifies
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Last modified: May 25, 2011