Denise Renee Lingwall - Page 7

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               Section 6330(c)(2) outlines the issues that a person may               
          raise at an administrative hearing.  Those issues include                   
          appropriate spousal defenses, challenges to the appropriateness             
          of the Commissioner's intended collection action, and possible              
          alternative means of collection.  Section 6330(c)(4) bars a                 
          person from raising at an administrative hearing an issue that              
          was raised and considered at a previous administrative or                   
          judicial proceeding if the person seeking to raise the issue                
          “participated meaningfully” in such hearing or proceeding.                  
               Section 6330(d) provides for judicial review of the                    
          administrative determination in the Tax Court or Federal district           
          court, as appropriate.                                                      
          Claims for Relief From Joint and Several Liability                          
               Section 6013(d)(3) provides that if a husband and wife make            
          a joint Federal income tax return, “the tax shall be computed on            
          the aggregate income and the liability with respect to the tax              
          shall be joint and several.”  Section 6015(a) provides, however,            
          that, notwithstanding section 6013(d)(3), an individual who has             
          made a joint return may elect to seek relief from joint and                 
          several liability on such return.                                           
               Congress vested this Court with jurisdiction to review a               
          taxpayer’s election to claim relief from joint and several                  
          liability on a joint return under varying circumstances.  See               
          King v. Commissioner, 115 T.C. 118, 121-122 (2000); Corson v.               

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