Diane Fernandez - Page 2




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               innocent spouse relief.  R’s motion to strike P’s                      
               allegations of fact is denied.                                         

               Francine K. Cardella, for petitioner.                                  
               Rose E. Gole, for respondent.                                          

                                       OPINION                                        

               COHEN, Chief Judge:  This case was assigned to Chief Special           
          Trial Judge Peter J. Panuthos pursuant to the provisions of                 
          section 7443A(b)(5).  Unless otherwise indicated, section                   
          references are to the Internal Revenue Code as amended, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.  The Court agrees with and adopts the opinion of the             
          Special Trial Judge, which is set forth below.                              
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               PANUTHOS, Chief Special Trial Judge:  This matter is before            
          the Court on respondent’s motion to dismiss for lack of                     
          jurisdiction and to strike.  The issues for decision are: (1)               
          Whether this Court has jurisdiction to review the denial of a               
          request for innocent spouse relief pursuant to section 6015(f);             
          and (2) whether certain allegations of fact asserted in the                 
          petition are relevant to petitioner’s request for innocent spouse           
          relief.                                                                     










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