- 3 -
1982, 1983, and 1984, for which she and her spouse (Mr. Ordlock)
filed joint Federal income tax returns. The following table
provides the specific adjustments for each taxable year in issue
as stated in the notice of determination:
Amount of relief Amount of relief Amount of
Tax Period(s) you requested we could allowtax remaining
12/31/1982 $314 ($621) -0-
12/31/1983 80,081 54,208 -0-
12/31/1984 132,606 132,601 -0-
The notice of determination further specifies that “We’ve granted
your request in full, you don’t have to take any further action.”
On November 1, 2002, the date the petition was filed,
petitioner resided in Anaheim, California.2 In her petition,
petitioner, through her attorney, alleged that
The Commissioner has apparently determined to allow
Petitioner’s request in full, but the Notice [of
determination] does not expressly state that
Petitioner’s request is allowed in full, and the Notice
[of determination] contains various erroneous amounts
and calculations which misstate and miscalculate the
amounts of relief for which Petitioner is eligible
under Code Section 6015(b). The effect of these
misstatements and miscalculations is that the Notice
[of determination] does not allow Petitioner’s request
for relief in full. Therefore, this petition is
necessary in order to verify that the Commissioner
intended to allow Petitioner’s request in full and to
correctly determine and state the full amount of relief
for which Petitioner is eligible under Code Section
6015(b).
2We note that petitioner’s petition was postmarked Oct. 24,
2002, and was therefore timely.
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