Denise Renee Lingwall - Page 5

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          Hearing under section 6330, in which she asserted that her former           
          spouse was responsible for the unpaid taxes.                                
               On February 18, 2004, respondent issued to petitioner a                
          Notice of Determination Concerning Collection Action(s)                     
          (Determination Notice) that acknowledged petitioner asserted in             
          her collection hearing request that her former spouse was                   
          responsible for the tax liabilities.  Respondent explained,                 
          however, that because petitioner had “been through the Innocent             
          Spouse claim process, you know that both you and your ex-spouse             
          are separately responsible for the entire amount of the joint               
          liability.”  The Determination Notice also stated that petitioner           
          failed to raise an appropriate spousal defense.  Respondent                 
          determined in the Determination Notice that the filing of the               
          notice of Federal tax lien was appropriate.                                 
               On March 19, 2004, petitioner filed with the Court a                   
          petition for lien or levy action challenging respondent’s                   
          Determination Notice.2  Petitioner’s sole contention is that she            
          paid her fair share of the unpaid tax liabilities.                          
               As previously mentioned, respondent filed a Motion for                 
          Summary Judgment.  Petitioner filed an objection to respondent’s            
          motion on May 5, 2005, repeating her assertion that her former              
          spouse is responsible for the tax liabilities.                              

               2  The parties do not dispute that the petition in this case           
          was timely filed under secs. 6330 and 7502(a).                              

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