- 5 -
Following the change in the applicable law, respondent was
ordered to file a written report on respondent's position with
respect to petitioner's claim for relief under the new law. In
respondent’s report, he stated: "In light of the aforementioned
change in the law, it appears to respondent that petitioner
qualifies for innocent spouse relief under the provisions of
section 6015(b)." Respondent further stated that petitioner's
former spouse, Mr. Freeman, objected to such relief and that Mr.
Freeman "should be provided with adequate notice and an
opportunity to become a party to this proceeding" and cited
section 6015(e)(4). The Court then directed respondent to serve
Mr. Freeman with a copy of the petition and a copy of Interim
Rule 325.2 Thereafter, within the time prescribed in Interim
Rule 325, Mr. Freeman submitted to the Court a document that was
filed as a Motion For Leave to File Notice of Intervention
2Interim Rule 325 provides:
(a) Notice: The Commissioner shall serve notice
of the filing of the petition on the other individual
filing the joint return.
(b) Intervention: If the other individual filing
the joint return desires to intervene, then such
individual shall file a notice of intervention with the
Court not later than 60 days after service of the
notice by the Commissioner of the filing of the
petition, unless the Court directs otherwise, and
attach to the notice of intervention a copy of such
notice of filing. All new matters of claim or defense
in a notice of intervention shall be deemed denied.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011