Francisco E. Campos, Jr. and Lualhati N. Campos - Page 8

                                        - 8 -                                         
          sibling.  T.W. & M.W. v. Brophy, 124 F.3d 893, 897 (7th Cir.                
          1997); Eiges v. Commissioner, supra at 67.                                  
               As previously discussed, the record amply demonstrates that            
          Mr. Campos is unable to prosecute this action due to a medical              
          disability.  Moreover, as Mr. Campos’s spouse and de facto                  
          representative, Mrs. Campos has a sufficiently close relationship           
          with Mr. Campos to justify her recognition as next friend.                  
          Finally, although we recognize that conflicts of interest may               
          arise between spouses filing joint returns (see, e.g., sec.                 
          6015), we are persuaded on this record that Mrs. Campos will                
          represent the best interests of Mr. Campos in this proceeding.3             
               Consistent with the preceding discussion, and considering              
          all the facts and circumstances, we conclude that this is an                
          appropriate case for the Court to exercise its discretion under             
          Rule 60(d).  In an effort to promote the just, speedy, and                  
          inexpensive determination of this case, we shall grant Mrs.                 
          Campos’s pending motion in that we shall recognize Mrs. Campos as           










               3  There is no allegation in the petition that either spouse           
          is entitled to relief from joint and several liability on a joint           
          return under sec. 6015.                                                     





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