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v. Commissioner, supra; Himmelwright v. Commissioner, supra. For
example, in Garvey v. Commissioner, supra, this Court was faced
with a controversy having a procedural posture nearly identical
to that of the instant case. The Court declined, however, to
interfere with the parties’ settlement negotiations and granted
the Commissioner’s motion for entry of decision. See id.
In deciding Garvey v. Commissioner, supra, the Court also
relied on the earlier opinion issued in Himmelwright v.
Commissioner, supra. In that case, Mr. Himmelwright likewise
objected to the Commissioner’s motion for entry of decision
following his own settlement with the Commissioner and a
settlement between the Commissioner and Ms. Himmelwright granting
her relief under section 6013(e). See id. Mr. Himmelwright
argued that he settled believing his wife would share the tax
burden, but the Court, observing that his agreement was not
contingent upon resolution of Ms. Himmelwright’s claim, saw no
reason to reject the Commissioner’s concession. See id.
A similar viewpoint was taken by the Court of Appeals for
the Ninth Circuit, to which appeal in the instant case would
normally lie. See Estate of Ravetti v. United States, supra at
1395-1396. In Estate of Ravetti v. United States, supra at 1395,
the Court of Appeals noted the basic proposition that “A taxpayer
generally has no standing to challenge the tax liability
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