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respect to respondent’s motion.
The validity of the underlying tax liability for 1990 is not
at issue here. Consequently, we shall review the determinations
set forth in the notice of determination under an abuse-of-
discretion standard. See Sego v. Commissioner, 114 T.C. 604, 610
(2000).
In support of his position that the Appeals Office erred in
determining that respondent may proceed to collect from him the
unpaid portion of the assessed 1990 tax deficiency, petitioner
argues that respondent should have given him notice of and an
opportunity to participate in the administrative proceedings
regarding Ms. Bacon’s application for relief from joint and
several liability with respect to that deficiency and that
respondent should not have granted such relief to Ms. Bacon.
In respondent’s motion, respondent counters:
7. Petitioner does not have standing to challenge
respondent’s determination that his former wife is an
innocent spouse. See Estate of Ravetti v. United
States, 37 F.3d 1393 (9th Cir. 1994) and Garvey v.
Commissioner, T.C. Memo. * * * [1993-354].
* * * * * * *
10. In the instant case, * * * the Commissioner
granted innocent spouse relief to petitioner’s former
wife before the enactment of the Internal Revenue
Restructuring and Reform Act of 1998. Thus, peti-
tioner’s former wife never made an election under
I.R.C. � 6015(b) or (c), section 6015(e)(4) does not
apply to this case, and the pre-1998 Act precedent of
Estate of Ravetti and Garvey, supra, forecloses peti-
tioner’s challenge to his former wife’s innocent spouse
status.
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