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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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