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The Court entered a decision on May 16, 2003, in docket No.
9654-02L, pursuant to a stipulation between petitioner and
respondent, relating to the collection of petitioner’s income tax
liabilities for 1995, 1996, 1997.
Request for Innocent Spouse Relief
Respondent received from petitioner on June 3, 2002, a Form
8857, Request for Innocent Spouse Relief, in which petitioner
requested relief from joint and several liability under section
6015(c) and (f) for 1995, 1996, and 1997.
A Notice of Determination Concerning Your Request for Relief
from Joint and Several Liability under Section 6015 (notice of
determination) denying petitioner’s request was issued to
petitioner on January 12, 2005.
Present Proceeding
On April 18, 2005, petitioner filed with the Court a
petition seeking a review of the notice of determination denying
her request for relief from joint and several liability under
section 6015 for 1995, 1996, and 1997.
Respondent filed a motion to file answer out of time to
allege the application of res judicata under section 6015(g)(2)
for 1995 and 1996. Petitioner filed an objection, and respondent
filed a response to petitioners’s objection. A hearing was held,
and the Court granted respondent’s motion to file an answer out
of time to allege the application of section 6015(g)(2).
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