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deficiency. Accordingly, on May 6, 2002, respondent assessed
the determined deficiency.
On September 24, 2002, petitioner requested a collection due
process hearing; however, his request was denied as untimely.
Petitioner did subsequently receive an equivalent hearing.
Petitioner filed a Form 8857, Request for Innocent Spouse
Relief, on April 30, 2004. On November 16, 2004, the Internal
Revenue Service’s Examination Division denied petitioner’s claim
for relief under section 6015(b), (c), and (f). Although
petitioner appealed to respondent’s Office of Appeals, a notice
of determination was sent to petitioner on February 14, 2005.
The notice denied petitioner relief from joint liability for the
taxable year 1999.
Intervenor filed a Form 8857 on July 28, 2002. That request
was subsequently denied. On November 26, 2003, a notice of
determination was sent to intervenor. Intervenor did not take
any action with respect to that notice.
Respondent, pursuant to Rule 325 and King v. Commissioner,
115 T.C. 118 (2000), served notice of this proceeding on
intervenor. Intervenor filed a notice of intervention on August
30, 2005. She was not present at trial, but was represented by
counsel. Intervenor filed a motion to dismiss at trial. In her
motion, intervenor contends that petitioner’s claim for innocent
spouse relief should be dismissed because she never signed the
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