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jurisdiction for the purpose of reviewing respondent’s
administrative determination.
Section 6015(h)(2) contemplates that petitioner be given
notice of, and the opportunity to participate in, administrative
proceedings addressing Ms. Maier’s election to claim relief from
joint and several liability.7 The record shows that petitioner
was notified of Ms. Maier’s claim and that he was permitted to
submit information to respondent relative to that claim.
Although petitioner remains dissatisfied with the level of
participation afforded him during the administrative process,
there is no directive in section 6015, or any other statutory
7 Sec. 1.6015-6(a)(1), Income Tax Regs., provides in
pertinent part:
�1.6015-6. Nonrequesting spouse’s notice and
opportunity to participate in administrative
proceedings.–-(a) In general–-(1) When the Secretary
receives an election under �1.6015-2 or 1.6015-3, or a
request for relief under �1.6015-4, the Secretary must
send a notice to the nonrequesting spouse’s last known
address that informs the nonrequesting spouse of the
requesting spouse’s claim for relief. The notice must
provide the nonrequesting spouse with an opportunity to
submit any information that should be considered in
determining whether the requesting spouse should be
granted relief from joint and several liability. A
nonrequesting spouse is not required to submit
information under this section. * * *
(2) The Secretary must notify the nonrequesting
spouse of the Secretary’s final determination with
respect to the requesting spouse’s claim for relief
under section 6015. * * *
Sec. 1.6015-6(b), Income Tax Regs., sets forth a
nonexclusive list of the matters that a nonrequesting spouse
might include in information submitted to the Secretary.
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Last modified: May 25, 2011