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Thorpe. Once again, petitioner did not return the Form 8857 to
the Appeals Office, and at the time of trial he had not filed a
Form 8857 with the Internal Revenue Service.
Petitioner’s divorce from Mrs. Thorpe was finalized on March
12, 2002, by the Illinois Circuit Court in Winnebago County,
Illinois. The divorce decree ordered that the income tax debt be
split evenly between petitioner and Mrs. Thorpe. Mrs. Thorpe was
awarded custody of the couple’s only child, subject to
petitioner’s “reasonable and seasonable visitation”, and
petitioner was ordered to pay child support of $116 weekly.
Petitioner’s case was assigned to an Appeals officer from
respondent’s Appeals Office in Peoria, Illinois. On February 20,
2003, petitioner discussed his case with the Appeals officer
during a telephone conference. The record is silent as to the
substance of this telephone conference, except as quoted below in
an excerpt from the notice of determination.
On April 14, 2003, the Appeals officer issued to petitioner
a Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 (notice of determination), in which he
sustained the proposed levy to collect petitioner’s 1997 tax
liability. The notice of determination set forth the following
explanation regarding the Appeals officer’s consideration of
petitioner’s request that liability on his 1997 joint return be
shared equally with his former wife:
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