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Respondent failed to inform petitioner of her right to apply for
relief under section 6015 as required by RRA 1998 sec. 3501(b),
112 Stat. 770. Therefore, we hold that respondent abused his
discretion when he denied petitioner’s request for relief under
section 6015(f) by applying the 2-year limitation period of Rev.
Proc. 2000-15, sec. 5, 2000-1 C.B. 447, 449. McGee v.
Commissioner, supra.
In reaching our holding herein, we have considered all
arguments made, and, to the extent not mentioned above, we
conclude that they are moot, irrelevant, or without merit.
To reflect the foregoing,
An appropriate
order will be issued.
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Last modified: May 25, 2011