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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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