Thomas B. Russell, Senior Judge United States District CourtMEMORANDUM OPINION
The United States brought this action in 2013 against Matthew and Deborah Stein to recover unpaid federal income taxes. In the time since, Matthew has conceded his liability for the debt, but Deborah continues to resist the United States' efforts to reduce the assessments made against her to judgment. She anchors her opposition on the equitable "innocent spouse" exemption codified at I.R.C. § 6015(f). According to the United States, however, Deborah's argument is of no moment because the Court is without jurisdiction to allow such an exemption. The Court agrees. Because the Internal Revenue Service should be allowed to consider Deborah's claim in the first instance, the United States' Motion for Summary Judgment (R. 26) is GRANTED and Deborah Stein's Motion for Summary Judgment (R. 27) is DENIED.