Angela Rae Zachry, Petitioner, and Curtis Carlin, Intervenor - Page 7

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          Commissioner, 78 T.C. 100, 129 (1982) (citing Bruner v.                     
          Commissioner, 39 T.C. 534, 537 (1962); Neeman v. Commissioner, 13           
          T.C. 397, 399 (1949), affd. per curiam 200 F.2d 560 (2d Cir.                
          1952); Casey v. Commissioner, 12 T.C. 224, 227 (1949); Bonner v.            
          Commissioner, T.C. Memo. 1979-435; Ballenger v. Commissioner,               
          T.C. Memo. 1955-171).                                                       
               Relief from joint and several liability is available to                
          certain taxpayers under section 6015.  There are three avenues              
          for relief available under this section–-section 6015(b), (c),              
          (f).  In reaching the decision at the administrative level in               
          this case, the Appeals officer denied relief under subsections              
          (b) and (c) finding that petitioner had actual knowledge.  The              
          Appeals officer also denied relief under subsection (f) noting:             
                    While no formal request under 6015(f) was                         
               received during the CDP process, the taxpayer’s                        
               statements all concerned the inequity of holding her                   
               liable and her inability to pay.  The taxpayer                         
               provided no financial information so Appeals could                     
               make no determination as to the hardship provisions                    
               of 6015(f) * * *.  Appeals considered the taxpayer’s                   
               statements about the inequity of holding her liable,                   
               but her bare statements alone were insufficient to                     
               overcome the prior denial of relief.  Both the                         
               taxpayer and her POA were given time to supply                         
               additional supporting documentation and chose not to                   
               do so.                                                                 
          The Appeals officer sustained the levy action.  This Court will             
          reverse the Appeals officer’s finding only if petitioner                    
          establishes there was an abuse of discretion.                               







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