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request for relief under section 6015 would be denied, that the
Appeals Office would issue to Ms. Hollen a notice of determina-
tion denying that request, and that Ms. Hollen would have the
opportunity to petition the Tax Court for review of that determi-
nation. During the October 20, 2005 call, the settlement officer
asked to speak with Mr. Hollen, but Ms. Hollen indicated that he
was at work. During that call, the settlement officer also
indicated that Mr. Hollen and Ms. Hollen would each receive a
notice of determination with respect to the notice of intent to
levy and the notice of tax lien.
On October 28, 2005, the Appeals Office issued to Ms. Hollen
a “Notice of Determination Concerning Your Request for Relief
from Joint and Several Liability under Section 6015” (notice of
determination under section 6015) with respect to Ms. Hollen’s
Form 8857 in which the Appeals Office denied Ms. Hollen’s request
for relief under section 6015. On October 28, 2005, the Appeals
Office sent a letter to Mr. Hollen notifying him that it had made
a determination to deny that request.
On October 28, 2005, the Appeals Office issued to each
petitioner a notice of determination concerning collection
action(s) under section 6320 and/or 6330 (notice of determination
under sections 6320 and 6330) with respect to petitioners’
taxable year 1988. Those notices were identical and stated in
pertinent part:
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Last modified: November 10, 2007