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because, although not signed by petitioner, it was signed with
his consent. Mr. Guerrero then determined that petitioner had no
knowledge or reason to know of the understatement on the basis of
his limited education and alleged lack of involvement in the
financial affairs of the corporation.
Thereafter, this Court decided King v. Commissioner, 115
T.C. 118 (2000). In accordance with the holding in that case,
respondent on November 1, 2000, mailed a notice to Mrs. Ishizaki
informing her of her right to intervene in the instant
proceeding. Mrs. Ishizaki filed a notice of intervention with
the Court on December 19, 2000, wherein she disputed petitioner’s
entitlement to relief under section 6015.
Trial was held on March 28, 2001, and both petitioner and
Mrs. Ishizaki appeared, were represented by counsel, and offered
testimony. Following trial, all three parties submitted opening
posttrial briefs; respondent alone filed a reply brief. The body
of petitioner’s brief cites and discusses only repealed section
6013(e)(1), but a sheet attached to the brief and labeled “POINTS
AND AUTHORITIES IN SUPPORT OF PETITIONER’S CONTENTION HE IS AN
INNOCENT SPOUSE” cites section 6015(b) and enumerates its
requirements. No mention is made of other provisions of section
6015. Mrs. Ishizaki and respondent both take the position on
brief that petitioner is not entitled to relief from joint and
several liability.
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