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Leave to File Notice of Intervention. R filed a notice
of no objection to H's motion. P did not respond.
Held: In any case where an individual petitioner
seeks relief from joint liability pursuant to sec.
6015, I.R.C., the other individual who filed the joint
return is entitled to notice and, if not already a
party in the case, an opportunity to intervene for
purposes of challenging the propriety of relieving the
petitioner of liability.
Held, further, H is entitled to intervene in order
to challenge P’s entitlement to relief under sec. 6015,
I.R.C. The record will be reopened, and the case will
be calendared for further trial solely with respect to
the issue of relief from joint liability. H's motion
will be granted.
Held, further, additional procedural requirements
in proceedings before this Court are set forth as
guidance to taxpayers and counsel.
Kathy A. King, pro se.
James R. Rich, for respondent.
OPINION
RUWE, Judge: The matter before the Court is a Motion For
Leave to File Notice of Intervention (Embodying Notice of
Intervention) by Curtis T. Freeman (Mr. Freeman) with respect to
petitioner’s claim for relief from joint liability under section
6015.1
1Unless otherwise indicated, section references are to the
Internal Revenue Code, and Rule references are to the Tax Court
(continued...)
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