Estate of Edward Wenner - Page 8




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          Court, and we hold we require no additional jurisdiction to                 
          address Ms. Clark’s claim for section 6015 relief.2  Consequently           
          we shall deny respondent’s motion to strike paragraph 16 from the           
          petition and paragraph 2 of petitioners’ prayer for relief.                 
               To reflect the foregoing,                                              
                                             An appropriate order will                
                                        be issued.                                    




























               2We, however, do not have jurisdiction over the correctness            
          of the underlying deficiency determination in the instant                   
          proceeding.                                                                 





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