Hale Exemption Trust - Page 8




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               Here, as in Corson, we hold that Sharon Hale, as Thomas’               
          successor in interest, is entitled to participate in the judicial           
          review of the decision granting relief to Sylvia under section              
          6015(c).  To grant respondent’s motion would effectively preclude           
          the nonelecting spouse’s right to participate in the judicial               
          review of respondent’s determination.  We will, therefore, deny             
          respondent’s motion to enter a decision.  To reflect the                    
          foregoing,                                                                  


                                             An appropriate order will be             
                                        issued.                                       





























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Last modified: May 25, 2011