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requesting spouse’s petition for section 6015 relief and that the
nonrequesting spouse has a right to intervene in the case by
filing a notice of intervention with the Tax Court. See also
King v. Commissioner, 115 T.C. 118 (2000) (holding that the
nonrequesting spouse is entitled to notice and, if not already a
party, an opportunity to intervene to challenge the propriety of
relieving the requesting spouse of liability).
In Corson v. Commissioner, supra, the taxpayers (Mr. and
Mrs. Corson) filed a joint petition for redetermination with this
Court. Mrs. Corson later amended the petition to assert a claim
for section 6015 relief. Id. at 355-356. Mrs. Corson and the
Commissioner subsequently entered a stipulation in which Mrs.
Corson conceded liability for the deficiency but preserved her
right to pursue her claim for section 6015 relief. Mr. Corson
and the Commissioner signed a similar stipulation settling all
the issues pertaining to Mr. Corson’s tax liability for the year
in issue. Id. at 356-357. After the first two stipulations had
been entered, Mrs. Corson and the Commissioner executed a third
stipulation granting Mrs. Corson complete section 6015 relief.
When Mr. Corson refused to sign a stipulated decision based on
the stipulation granting Mrs. Corson complete section 6015
relief, the Commissioner filed a motion for entry of decision.
In denying the Commissioner’s motion for entry of decision, we
held that the nonrequesting spouse should be afforded an
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