Dorene Bulger - Page 5

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          and several liability for 1982 to 1997.4  Petitioner attached a             
          supporting statement to the request in which she represented that           
          she was not involved in the SGE investment and did not                      
          financially benefit from it.  Petitioner argued that she met each           
          requirement of section 6015(b) and, in particular, that she did             
          not understand the partnership transactions and had no knowledge            
          or reason to know of the understatements attributable to the Hoyt           
          partnership items on the joint returns.                                     
               On August 21, 2001, respondent sent petitioner a preliminary           
          determination letter denying petitioner’s request for relief                
          under section 6015 for taxable years 1982 through 1987.5                    
          Respondent advised petitioner of her right to administratively              
          appeal the decision.                                                        
               On or about September 17, 2001, petitioner administratively            
          appealed respondent’s denial of relief from joint and several               
          liability under section 6015(b) and (f).  Petitioner filed Form             
          12509, Statement of Disagreement, in which she summarized the               
          facts and law in support of her request for relief.  Petitioner             
          maintained that she had no knowledge or reason to know of the               


               4There are no income tax assessments against petitioner for            
          1982 and 1983, and no understatements of tax have been assessed             
          for 1988 through 1997.                                                      
               5The preliminary determination letter references “enclosed             
          Form 886-A” as providing an explanation of why respondent denied            
          relief.  Form 886-A, Explanation of Items, was not included in              
          the exhibits or attachments by either party.                                





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