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deficiency, and respondent assessed the tax deficiency and
statutory additions. Thereafter, petitioner sought relief under
section 6015. On February 11, 2003, respondent mailed to
petitioner a final notice advising him that his requested section
6015 relief had been denied and that if he wished to contest this
determination, he must file a petition with the U.S. Tax Court
within 90 days. This Court’s jurisdiction to review petitioner’s
claim for relief is conferred by section 6015(e), which allows a
spouse who has requested relief from joint and several liability
to contest the Commissioner’s denial of relief by filing a timely
petition in this Court. Petitioner filed a timely petition with
this Court on March 25, 2003.
On May 22, 2003, respondent filed an answer to petitioner’s
petition and a certification under Rule 325(b), as amplified by
King v. Commissioner, 115 T.C. 118 (2000). The certification
confirmed that respondent had notified Ms. Cullen that petitioner
had filed a claim for relief from joint and several liability and
that she could intervene. Despite the notice, Ms. Cullen has not
intervened in this case.
OPINION
I. Contentions of the Parties
Petitioner contends that he is eligible for relief from
joint and several liability under section 6015(b), (c), or (f)
for the 1999 tax liability and statutory additions. In essence,
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