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On January 18, 2002, respondent issued to petitioner a
notice of determination denying her claim for relief from joint
and several liability for the taxable years 1992 to 1995. The
notice stated that petitioner was denied relief under section
6015(f). On October 23, 2003, respondent issued to petitioner a
notice of determination denying her claim for relief from joint
and several liability for the taxable years 1992 to 1996. The
notice stated that petitioner was denied relief under section
6015(b), (c), and (f). On January 21, 2004, petitioner filed
with the Court a petition for determination of relief from joint
and several liability on a joint return challenging respondent’s
notice of determination dated October 23, 2003.2
On March 8, 2004, respondent filed with the Court a notice
of filing petition and right to intervene (the notice). The
notice stated that respondent had informed Mr. Murray of the
filing of the petition and of his right to intervene in the case.
The notice stated in pertinent part: “Under T.C. Rule 325(b),
Stanley D. Murray has a right to intervene in this matter for the
sole purpose of challenging petitioner’s entitlement to relief
from joint and several liability.”
On March 15, 2004, petitioner filed a Motion to strike the
notice on the ground that respondent “misinterprets and/or
misconstrues Tax Court Rule 325(b)” insofar as the notice stated
2At the time the petition was filed, petitioner resided in
Scottsdale, Arizona.
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Last modified: May 25, 2011