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however, that petitioner contends that she is entitled to reopen
the record for the Court to receive evidence as to petitioner's
entitlement to proportionate relief pursuant to section
6015(b)(2), and except that petitioner contends that she is
entitled to equitable relief pursuant to section 6015(f).
Petitioners' Claim for Innocent Spouse Relief Pursuant to Section
6015(b)(1)
Generally, spouses filing a joint tax return are each fully
responsible for the accuracy of their return and for the full tax
liability. See sec. 6013(d)(3). The innocent spouse provisions
of section 6015 provide exceptions to the general rule in certain
circumstances. Section 6015 provides, in pertinent part, as
follows:
SEC. 6015. RELIEF FROM JOINT AND SEVERAL LIABILITY ON JOINT
RETURN.
(a) In General.--Notwithstanding section 6013(d)(3)–-
(1) an individual who has made a joint return may elect
to seek relief under the procedures prescribed under
subsection (b) * * *
* * * * * * *
(b) Procedures for Relief from Liability Applicable to All
Joint Filers.--
(1) In general.--Under procedures prescribed by the
Secretary, if–-
(A) a joint return has been made for a taxable
year;
(B) on such return there is an understatement of
tax attributable to erroneous items of one individual
filing the joint return;
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