Kelly Sue Tipton, Petitioner, and Darren L. Darilek, Intervenor - Page 4

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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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