Denise Renee Lingwall - Page 8

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          Commissioner, 114 T.C. 354, 363-364 (2000).  As relevant in this            
          case, a person may file a so-called stand alone petition seeking            
          relief from joint and several liability on a joint return in                
          response to the Commissioner’s final notice disallowing a claim             
          for relief.  See sec. 6015(e)(1); Mora v. Commissioner, 117 T.C.            
          279 (2001).  Such a petition must be filed within 90 days of the            
          date that the Commissioner mailed the final notice disallowing              
          relief.  Sec. 6015(e)(1)(A).                                                
               The record in this case reflects that respondent issued a              
          final notice to petitioner disallowing her claim for relief from            
          joint and several liability for 1997 and 1998 in August 2001.               
          Petitioner did not file, however, a petition with the Court                 
          challenging respondent’s determination.  Petitioner does not                
          allege that the final notice was not mailed to her correct                  
          address.  In any event, the 90-day period in which petitioner               
          could have invoked this Court’s jurisdiction under section                  
          6015(e) has long since expired.                                             
               Under the circumstances, we conclude that the Appeals Office           
          correctly determined that section 6330(c)(4) barred petitioner              
          from attempting to resurrect her claim for relief under section             
          6015 during her collection review hearing initiated under section           

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