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Liability and Equitable Relief), requesting relief pursuant to
section 6015(b), (c), or (f) for the taxable year 1983. On
August 9, 2000, respondent sent petitioner an initial letter
(Letter 3277) notifying her that she was not entitled to relief
under section 6015(b) for the taxable year 1983. On September
22, 2000, petitioner sent a protest letter to respondent in
response to respondent’s notification letter outlining the
reasons that petitioner believed respondent’s determination was
incorrect.
Petitioner submitted a Form 433-A, Collection Information
Statement for Wage-Earners and Self-Employed Individuals, to
respondent on September 12, 2003. In petitioner’s Form 433-A,
she reported assets totaling $197,155 (including the Lampe home
valued at $183,000). Petitioner had no outstanding liabilities
and also reported gross monthly earnings of $2,061 and living
expenses of $1,674. Mr. Campbell also reported his assets and
liabilities in the Form 433-A.
Final Notice of Determination
On January 23, 2004, the Appeals Office sent to petitioner a
Notice of Determination Concerning Your Request for Relief From
Joint and Several Liability Under Section 6015 (notice of
determination) denying petitioner’s request for relief from joint
and several liability. The notice of determination denied relief
only under section 6015(f) and did not mention section 6015(b).
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