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allocation and that none of the other limitations apply; i.e.,
disqualified asset transfers).
Petitioner did not establish that the IRS’s $704.88
computation was incorrect or that a more favorable calculation
was appropriate. See sec. 1.6015-3(d)(4)(i) and (ii), (5), and
(6), Income Tax Regs. (discussing proportionate allocation, the
allocation of separate return items and their effect on the
requesting spouse’s liability, and alternative allocation
methods). Therefore, petitioner is not entitled to relief under
section 6015(c) with respect to the $704.88 for which respondent
found her liable.5 Accordingly, respondent’s determination with
respect to the $704.88 for 2000 under section 6015(c) is
Section 6015(f): Equitable Relief
The IRS may relieve an individual from joint and several
liability under section 6015(f) if, taking into account all the
facts and circumstances, it is inequitable to hold the taxpayer
5 Whether petitioner qualifies for sec. 6015(f) relief
with respect to the $704.88 is discussed below. See Hopkins v.
Commissioner, 121 T.C. 73 (2003) (applying Rev. Proc. 2000-15;
the taxpayer received partial relief under sec. 6015(c), and the
Court went on to review the disallowed portion under sec.
6015(f)); Capehart v. Commissioner, T.C. Memo. 2004-268 (same),
affd. 204 Fed. Appx. 618 (9th Cir. 2006); Rowe v. Commissioner,
T.C. Memo. 2001-325 (same); cf. Baumann v. Commissioner, T.C.
Memo. 2005-31 (applying Rev. Proc. 2003-61; the IRS determined
that the taxpayer did not qualify for relief under sec. 6015(c)
because of her actual knowledge of the item but allowed partial
relief under sec. 6015(f)).
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Last modified: March 27, 2008