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$2,050.03, of which $389 was attributable to petitioner.
Petitioner and Mr. Toppi have not made any further payments on
their 1998 tax liability.
On October 22, 2000, petitioner and Mr. Toppi untimely filed
their joint 1999 tax return reporting a tax liability in the
amount of $7,437.52 and a withholding credit in the amount of
$4,904.49, of which $1,884 was attributable to petitioner.
Petitioner and Mr. Toppi have not made any further payments
against their 1999 tax liabilities.
On August 3, 2001, petitioner and Mr. Toppi signed a Form
900, Tax Collection Waiver, extending the period of limitations
for collection of their 1996, 1997, 1998, and 1999 tax
liabilities. On June 25, 2004, respondent received petitioner’s
Form 8857, Request for Innocent Spouse Relief, and Form 12510,
Questionnaire for Requesting Spouse, for tax years 1995 through
2001.1 On December 8, 2004, respondent’s Appeals officer sent
petitioner a letter requesting any additional information that
petitioner wanted respondent to consider in determining whether
petitioner was entitled to section 6015(f) relief for the years
in issue. On January 27, 2005, respondent’s Appeals Office sent
petitioner a Notice of Determination denying petitioner’s request
1The record does not demonstrate that petitioner and Mr.
Toppi have any tax liabilities for 2000 and 2001. We do not need
to address this because, for reasons explained below, we hold
that we do not have jurisdiction over the instant case.
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