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
(c) The tax liability is solely attributable to my
I respectfully request that you consider the above and
grant me equitable relief from the tax liabilities.
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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Last modified: November 10, 2007