- 12 - at that time, and (3) all bank statements and canceled checks that petitioner had with respect to any bank accounts that petitioner maintained individually, that Mr. Beatty maintained individually, or that they maintained jointly. On November 5, 2002, petitioner provided such documents to respondent’s repre- sentative. On November 4, 2003, petitioner and Mr. Beatty filed Form 656, Offer in Compromise. In response, an Internal Revenue Service (IRS) offer manager returned that form by letter dated November 21, 2003. That letter stated in pertinent part: We are returning your Form 656, Offer in Compro- mise for the following reason(s): An offer will not be considered while a bankruptcy proceeding is open. All required tax returns have not been filed. On August 19, 2004, respondent’s Appeals Office (Appeals Office) sent petitioner a “Notice of Determination Concerning Your Request for Relief under the Equitable Relief Provision of Section 6015(f)” (notice of determination). In the notice of determination, the Appeals Office denied petitioner relief under section 6015(f) with respect to, inter alia, taxable years 1988 through 1997 and 2000. The notice of determination stated in pertinent part: We’re writing to tell you that we’ve made a decision about your February 28, 2002 request for innocent spouse relief under Section 6015(f) of the Internal Revenue Code. * * *Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NextLast modified: November 10, 2007