Gwendolyn A. Ewing - Page 8

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               2.   Our Jurisdiction To Determine Whether the Taxpayer                
                    Qualifies for Relief Under Section 6015(f)                        
               Section 6015(f)4 authorizes the Secretary to prescribe                 
          procedures under which, taking into account all the facts and               
          circumstances, the Secretary may determine that it is                       
          inequitable to hold an individual jointly liable for tax.                   
          Section 6015(e)(1)(A)5 provides our jurisdiction in section 6015            
          cases.  Section 6015(e)(1)(A) provides that a taxpayer against              
          whom a deficiency has been asserted and who elects to have                  


               4  Sec. 6015(f) provides:                                              
                    SEC. 6015(f). Equitable Relief.--Under procedures                 
               prescribed by the Secretary, if--                                      
                         (1) taking into account all the facts                        
                    and circumstances, it is inequitable to hold                      
                    the individual liable for any unpaid tax or                       
                    any deficiency (or any portion of either);                        
                    and                                                               
                         (2) relief is not available to such                          
                    individual under subsection (b) or (c),                           
               the Secretary may relieve such individual of such                      
               liability.                                                             
               5  SEC. 6015(e). Petition for review by Tax Court.--                   
                    (1) In general.--In the case of an individual                     
               against whom a deficiency has been asserted and who                    
               elects to have subsection (b) or (c) apply--                           
                         (A) In general.--In addition to any other                    
                    remedy provided by law, the individual may                        
                    petition the Tax Court (and the Tax Court shall                   
                    have jurisdiction) to determine the appropriate                   
                    relief available to the individual under this                     
                    section if such petition is filed–                                





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