-16-
relief under section 6015(c). Thus, the procedures in section
6015(d) to allocate items between Hawthorne and Charlton apply.4
4 Sec. 6015(d) provides in part:
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 deficiency and allocable
to the individual under paragraph (3) bears to the
net amount of all items taken into account in
computing the deficiency.
(2) Separate treatment of certain items.--If a
deficiency (or portion thereof) is attributable to
–-
(A) the disallowance of a credit; or
(B) any tax (other than tax imposed by
section 1 or 55) required to be included with
the joint return,
and such item is allocated to one individual under
paragraph (3), such deficiency (or portion) shall be
allocated to such individual. Any such item shall not
be taken into account under paragraph (1).
(3) Allocation of items giving rise to the
deficiency. For purposes of this subsection-–
(A) In general. Except as provided in
paragraphs (4) and (5), any item giving rise
to a deficiency on a joint return shall be
allocated to individuals filing the return in
the same manner as it would have been
allocated if the individuals had filed
separate returns for the taxable year.
(B) Exception where other spouse benefits.
Under rules prescribed by the Secretary, an
(continued...)
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