Teresa G. Butner - Page 15

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               ship in or control over.  These unpaid tax liabilities                 
               are attributable to my non-requesting spouse.  I wish                  
               to present the following factors which I ask that you                  
                    (a) Had I filed a separate return, the tax liabil-                
               ity would not have been included in my return.                         
                    (b) The tax liability reported.  I did not know                   
               and had no reason to know that the liability would not                 
               be paid.                                                               
                    (c) The tax liability is solely attributable to my                
               spouse’s income                                                        
               I respectfully request that you consider the above and                 
               grant me equitable relief from the tax liabilities.                    
               [Reproduced literally.]                                                
               Around June 11, 2002, petitioner's respective Forms 8857               
          with respect to the taxable years 1994, 1995, 1998, and 1999 were           
          transmitted to the Appeals Office for further consideration.                
               By letter dated August 14, 2002, the Appeals Office acknowl-           
          edged receipt of petitioner's respective Forms 8857 for the                 
          taxable years at issue.  By letter dated March 19, 2003, an                 
          Appeals officer scheduled a telephonic conference for April 2,              
               At the time in June 2003 the Appeals officer considered                
          petitioner’s Forms 8857, petitioner owned a 2002 Chevrolet pickup           
          truck and a 2002 Chevrolet Tahoe sports utility vehicle.                    
               By letter dated June 16, 2003 (June 16, 2003 letter), the              
          Appeals officer advised petitioner's representative, William J.             
          Lawing, C.P.A., that although the Appeals officer had originally            
          indicated that petitioner might be entitled to full relief under            

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