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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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