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section 6015(f), "the facts of this case do not merit such a
determination." The Appeals officer noted in that letter that
most of the factors set forth in Revenue Procedure 2000-15, 2000-
1 C.B. 447 (Revenue Procedure 2000-15), weigh against relief. In
the June 16, 2003 letter, the Appeals officer informed petitioner
that, in order to change that conclusion, petitioner must provide
certain additional information. A response deadline of June 30,
2003, was given. On or after September 15, 2003, petitioner's
representative provided additional information to the Appeals
officer.
On or about August 28, 2003, the Appeals officer prepared an
Appeals Case Memorandum that set forth (1) all the facts and law
that she considered in determining to uphold respondent’s prelim-
inary determination to deny relief under section 6015 and (2) her
application of that law to those facts.
By letter dated September 11, 2003, and entitled "Subject:
Notice of Determination Concerning Your Request for Relief from
Joint and Several Liability under Section 6015", the Appeals
Office informed petitioner that she was not eligible for relief
under section 6015(b), (c), or (f).
At no time was petitioner abused by Mr. Butner. Nor has
petitioner verified at any time that she would suffer an economic
hardship if relief under section 6015 for the taxable years 1994,
1995, 1998, and 1999 were not granted.
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Last modified: November 10, 2007