- 2 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011