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liability. Respondent separately negotiated settlements with the
parties that included, for the former wife, relief from joint
liability. The granting of this relief was not previously
disclosed to her former husband. When the former husband became
aware of this concession, he refused to agree to the negotiated
settlement, whereupon respondent filed a motion for entry of
decision. In Corson, we noted that, in the context of a stand-
alone proceeding under section 6015(e)(1)(A), the other spouse is
entitled to notice and the opportunity to participate in the
consideration of the claim for relief by the electing spouse at
both the administrative level and in any subsequent judicial
proceeding before this Court. See section 6015(e)(4), (g)(2).
Even though Corson did not arise as a stand-alone proceeding, we
held that, pursuant to section 6015, the husband was entitled to
be heard on the question of his former wife’s claim for relief
from joint liability.
In the instant case, the claim for relief from joint
liability arises, as in Corson, in the context of a deficiency
proceeding. However, unlike Corson, in this case Mr. Freeman is
not a petitioner in this deficiency proceeding. Mr. Freeman did
not file a petition and, as a result, the deficiency was assessed
against him. In our view, this difference is not a material
distinction for purposes of deciding whether to allow Mr. Freeman
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