Ana Maria Rodriguez - Page 6

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          gambling winnings or the amount of the distribution from Mr.                
          Rodriguez’s IRA account.  Petitioner also asserts that she has no           
          knowledge of the tax laws.                                                  
               Respondent asserts that petitioner, who was granted relief             
          under section 6015(c), is not entitled to additional relief under           
          section 6015(f) from liability for tax on the $4,002 gambling               
          income and $15,500 IRA distribution, primarily because she had              
          actual knowledge of both amounts.  At trial, respondent asserted            
          that petitioner could not be considered for relief under section            
          6015(f), since she had been granted partial relief under section            
          6015(c).  In a supplemental memorandum respondent conceded that             
          petitioner could be considered for relief under such                        
          circumstances.  Nevertheless, respondent asserts that, taking               
          into consideration all the factors under section 6015(f),                   
          petitioner is not entitled to relief.                                       
                                   Discussion                                         
               Generally, married taxpayers may elect to file a joint                 
          Federal income tax return.  Sec. 6013(a).  After making the                 
          election, each spouse is jointly and severally liable for the               
          entire tax due.  Sec. 6013(d)(3).  A spouse may seek relief from            
          joint and several liability under section 6015.  A spouse may               
          qualify for relief from liability under section 6015(b), or, if             
          eligible, may allocate liability under section 6015(c).  In                 
          addition, if relief is not available under section 6015(b) or               






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