- 11 - trial was held on May 17, 1999, well after the effective date of section 6015.11 We find it remarkable that petitioner argues that he was not aware that he had to claim relief from joint and several liability at trial because under the prior law, in petitioner’s belief, such claim was typically submitted after trial, which belief is clearly erroneous. Indeed, the matter was called to the parties’ attention in the prior proceeding when the Court inquired whether Ms. Pena would be claiming relief from joint and several liability (which she did not). Petitioner was on notice that he also could raise a claim for joint and several liability, but he did not. As such, it follows that section 6015(g)(2) precludes petitioner from claiming relief from joint and several liability under section 6015(f). For the reasons stated, we shall grant respondent’s motion for summary judgment. We have considered all of the other arguments made by petitioner, and, to the extent that we have not specifically addressed them, we conclude that they are without merit. To reflect the foregoing, An appropriate order and decision will be entered. 11It might also be mentioned that although Ms. Trent appeared pro se in her deficiency action, petitioner was represented by counsel in his deficiency action.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
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