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upon him, as the nonelecting spouse, a right to
litigate in challenge of a decision by R to grant
relief under sec. 6015, I.R.C., to the electing spouse.
Held: T, the nonelecting spouse, should be
afforded an opportunity to litigate the decision by R
to grant relief from joint and several liability to J,
the electing spouse.
Held, further, respondent’s motion for entry of
decision will be denied.
Stephen Benda, for petitioner Thomas Corson.
Arthur A. Oshiro, for petitioner Judith Corson.
Robert H. Schorman, Jr., for respondent.
OPINION
NIMS, Judge: This matter is before the Court on
respondent’s motion for entry of decision. Broadly stated, the
issue to be resolved is whether objection by petitioner Thomas
Corson to respondent’s settlement with petitioner Judith Corson,
granting her relief under section 6015(c) from joint and several
liability, provides sufficient basis for the Court to deny
respondent’s motion for entry of decision. As more narrowly
framed by the contentions of the parties, the question raised is
whether provisions of the Internal Revenue Service Restructuring
and Reform Act of 1998 (Restructuring Act), Pub. L. 105-206, sec.
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