- 4 - 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 anPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011