Teresa G. Butner - Page 16

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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               
               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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