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liability of petitioner Joan L. Hollen (Ms. Hollen) for the tax,
(3) the propriety of filing a tax lien against Ms. Hollen,
(4) the timing of the tax lien filing, and (5) the possibility
that a “slander of title action” might be pursued against the
Internal Revenue Service (IRS) under Iowa law because the tax
lien filing was filed against Ms. Hollen.
During the May 6, 2005 conference, the settlement officer
addressed each of the issues that Mr. Hollen raised during that
conference. With respect to Mr. Hollen’s claim that Ms. Hollen
is not liable for the tax, the settlement officer advised Mr.
Hollen that if Ms. Hollen believed that she was not liable for
petitioners’ unpaid 1988 liability, she should file Form 8857,
Request for Innocent Spouse Relief (And Separation of Liability
and Equitable Relief) (Form 8857).
On May 16, 2005, the settlement officer received Form 8857
from Ms. Hollen (Ms. Hollen’s Form 8857). The settlement officer
forwarded Ms. Hollen’s Form 8857 to the IRS innocent spouse unit.
On October 18, 2005, the IRS innocent spouse unit notified the
settlement officer that it had concluded that Ms. Hollen was not
entitled to relief under section 6015. Thereafter, the settle-
ment officer began to prepare her determination with respect to
the notice of intent to levy and the notice of tax lien.
On October 20, 2005, the settlement officer called (October
20, 2005 call) Ms. Hollen and informed her that Ms. Hollen’s
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