Lisa Susan Kovitch, Petitioner, and Richard P. Kovitch, Intervenor - Page 5




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          267, 270 (2002), affd. 360 F.3d 361 (2d. Cir. 2004); see also               
          King v. Commissioner, supra at 121-122; Corson v. Commissioner,             
          114 T.C. 354, 363-364 (2000).  Claims for spousal relief can be             
          raised in several different types of proceedings including                  
          petitions filed under section 6015(e), 6330, or 6213.  Drake v.             
          Commissioner, 123 T.C. 320, 323 (2004); King v. Commissioner,               
          supra at 121-122.  Petitioner requested such relief by raising              
          the matter as an affirmative defense in a deficiency proceeding             
          under section 6213(a).  See Drake v. Commissioner, supra at 323;            
          see also Butler v. Commissioner, 114 T.C. 276, 287-288 (2000).              
               For cases involving requests for spousal relief, section               
          6015(e)(4) directs the Court to establish rules to provide notice           
          to the nonrequesting spouse and an opportunity to become a party            
          to the proceeding.  Pursuant to Rule 325 and King, Mr. Kovitch              
          was notified of petitioner’s petition seeking relief from joint             
          and several liability and of his right to intervene in                      
          petitioner’s case.  By intervening, Mr. Kovitch became a party.             
          See Tipton v. Commissioner, 127 T.C. 214, 217 (2006).  An                   
          intervening party is not granted rights or immunities superior to           
          those of the other parties, may not enlarge the issues or alter             
          the nature of the proceeding, and must abide by the Court’s                 
          Rules.  Id.  The instant proceeding concerns only whether                   










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