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On September 19, 2001, petitioner submitted to respondent a
Form 886-A, Innocent Spouse Questionnaire. Petitioner reported
monthly gross income of $3,715 and monthly expenses of $5,685.
Petitioner’s monthly expenses included, among other things, $300
for clothing, $700 for vehicle expenses, $240 for “pet care”, and
$400 in miscellaneous expenses.
On December 20, 2001, respondent issued petitioner an
initial determination letter. Respondent determined that
petitioner was not entitled to equitable relief under section
6015(f) for the years at issue, stating:
To qualify for relief under IRC Section 6015(f), you
must establish that you believed the tax would be paid
at the time of filing the return. Information in your
case file does not establish that you had belief that
the tax would be paid at the time of filing.
Therefore, your request for relief for the tax years *
* * [at issue] has been disallowed.
On March 4, 2002, respondent received from petitioner a Form
12509, Statement of Disagreement, in which petitioner repeated
her arguments set forth in her request for innocent spouse
relief.
On July 22, 2002, respondent advised petitioner that her
case had been received for consideration and identified Appeals
Officer Denise Neidermeyer (Ms. Neidermeyer) as the person
handling her case. Ms. Neidermeyer determined that “The taxpayer
knew or had reason to know that the tax would not be paid when
she signed the [1998 and 1999] returns. This is evidenced by the
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