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The Appeals officer adopted the tax auditor’s recommendation
against section 6015(f) relief. The Appeals team manager
approved the Appeals officer’s memorandum on November 12, 2002.
The notices of determination that are the basis of this action
were sent to petitioners on January 7, 2003.
On February 5, 2003, the Appeals officer received a letter
dated January 6, 2003, but postmarked February 3, 2003, from
Ms. Pless, which stated:
This letter is to inform you that I am recovering from
the cancer surgery that was performed on October 31,
2002. I am now able to ride without pain from sitting
and the risk of further complications. This will allow
me to reschedule for a hearing in January or February
2003. Previously, I had to reschedule the hearing
because of the necessary pre-surgical evaluations that
had led up to the April and October surgeries.
OPINION
Section 6330(c) specifies the issues to be considered at the
hearing requested by petitioners as follows:
SEC. 6330(c). Matters Considered at Hearing.--In
the case of any hearing conducted under this section--
* * * * * * *
(2) Issues at hearing.--
(A) In general.--The person may raise at
the hearing any relevant issue relating to
the unpaid tax or the proposed levy,
including--
(i) appropriate spousal defenses;
(ii) challenges to the
appropriateness of collection actions;
and
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Last modified: May 25, 2011