- 17 - often requests specific additional information and supporting documentation. If the financial information in the administrative file is more than 12 months old and/or the information is no longer accurate, the Appeals officer will request a new or updated financial statement before making the determination. See, e.g., Etkin v. Commissioner, T.C. Memo. 2005-245. Additionally, taxpayers’ entitlement to audio record section 6330 hearings, Keene v. Commissioner, 121 T.C. 8, 19 (2003), provides them a means of preserving an accurate record of the hearing. None of those safeguards is present under the Commissioner’s procedures for processing a taxpayer’s request for section 6015 relief. In September 2004, the Appeals officer determined that petitioner had not shown that she would suffer economic hardship if relief from the tax liabilities were not granted. However, in September 2002 petitioner had sent CCISO a completed questionnaire reporting unemployment compensation. Although unemployment compensation is temporary and most assuredly would have terminated by September 2004 when the Appeals officer made her determination, the Appeals officer did not request an updated financial statement from petitioner. Indeed, the Smiths’ joint return for 2003 reported only $3,888 of unemployment compensation, which indicates that the $1,280 of monthly unemployment compensation ended in early 2003.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NextLast modified: November 10, 2007