MEMORANDUM OPINION
LARO, Judge.
Respondent moves the Court for entry of decision. We must decide whether in the circumstances of this case the Internal Revenue Service Restructuring and Reform Act of 1998 (RRA), Pub. L. 105-206, sec. 3201, 112 Stat. 685, 734, allows a nonelecting spouse to seek judicial review of respondent's determination to grant the electing spouse relief from joint liability on a joint return. We hold it does.
Unless otherwise...
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