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and (f). Respondent opposed petitioner’s motion on grounds that
all issues had been settled in April 2003 and that it was too
late to assert such a claim.
On July 1, 2005, petitioner sent to respondent a separate
letter for each of the docketed cases indicating that she was
making a qualified settlement offer pursuant to section
7430(c)(4)(E) and (g). Petitioner offered to settle each case
for relief from any additional joint liability under section
6015(c). In addition, petitioner offered to make a payment of
$100 against any additional joint liability determined by
respondent for each of the tax years at issue. Respondent did
not respond to these offers.
On August 4, 2005, the Court granted petitioner’s motion for
leave to amend, and petitioner’s amended petitions were filed in
each docketed case. Respondent forwarded petitioner’s file to
the Internal Revenue Service Cincinnati Centralized Innocent
Spouse Operation (CCISO) for evaluation of her claim. Petitioner
submitted a completed questionnaire to CCISO, and on November 10,
2005, CCISO determined that petitioner was entitled to complete
relief from any deficiencies asserted in the docketed cases. On
December 5, 2005, respondent filed his answer denying
petitioner’s claim for relief under section 6015.
CCISO’s determination letter was eventually disclosed to
petitioner on April 3, 2006. On May 2, 2006, petitioner sent
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