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Request for Innocent Spouse Relief, with attachments.3
Petitioner included a letter with her Forms 12153 and 8857,
stating that she was “willing to take responsibility” for her
share of the amount of tax due.
Petitioner’s request for a collection due process hearing
and request for section 6015 relief were assigned to an Appeals
officer. In his initial letter to petitioner, the Appeals
officer requested that she provide him with all information she
wanted him to consider in making his determination. The Appeals
officer also requested that if petitioner wanted him to consider
an alternative collection method, she complete a Form 433-A,
Collection Information Statement for Wage Earners and Self-
Employed Individuals. Petitioner requested additional time to
gather the requested information, and she was given a deadline of
January 4, 2006, to respond. Despite being granted additional
time, petitioner did not provide any additional information to
respondent during the administrative hearing. Petitioner did not
propose any collection alternatives, nor did she challenge the
3 Petitioner’s Form 12153, Request for a Collection Due
Process Hearing, was filed timely as to the notice of Federal tax
lien but not as to the notice of intent to levy. Petitioner had
an equivalent hearing under sec. 301.6330-1(i), Proced. & Admin.
Regs., for the proposed levy action for tax years 1994 and 1995,
but respondent did not issue a notice of determination. At
trial, respondent moved to dismiss petitioner’s request for
judicial review of the levy action for lack of jurisdiction since
petitioner received an equivalent hearing, which is not subject
to judicial review. Because we granted respondent’s motion, the
levy action for tax years 1994 and 1995 is not at issue.
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Last modified: November 10, 2007