Marianne Hopkins - Page 15

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          deficiency for such year is asserted but not later than 2 years             
          after the date on which the Secretary has begun collection                  
          activities with respect to the individual making the election.              
          The applicable 2-year election period shall not expire before the           
          date that is 2 years after the first collection activity taken by           
          the IRS after the date of enactment.  Internal Revenue Service              
          Restructuring and Reform Act of 1998, Pub. L. 105-206, sec.                 
          3201(g)(2), 112 Stat. 740.  Petitioner elected relief on May 24,            
          1999, within the specified period.                                          
                    a.  Allocation of the Items Making Up the Deficiency              
               Section 6015(c)(1) provides that the allocation of a                   
          deficiency should be made as provided in section 6015(d).  Under            
          section 6015(d)(1), the portion of any deficiency on a joint                
          return allocated to an individual shall be the amount which bears           
          the same ratio to such deficiency as the net amount of items                
          taken into account in computing the deficiency and allocable to             
          the individual under section 6015(d)(3) bears to the net amount             
          of all items taken into account in computing the deficiency.17              


               17Sec. 6015(d)(1) provides:                                            
                    SEC. 6015(d).  Allocation of Deficiency.--For                     
               purposes of subsection (c)--                                           
                         (1)  In general.--The portion of any                         
                    deficiency on a joint return allocated to an                      
                    individual shall be the amount which bears the                    
                    same ratio to such deficiency as the net amount of                
                    items taken into account in computing the                         
                                                             (continued...)           




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