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portion). This subparagraph shall
not apply where the individual with
actual knowledge establishes that
such individual signed the return
under duress.
Section 6015(d) specifies how an allocation under section
6015(c) is to be made, providing in relevant part:
SEC. 6015(d). Allocation of Deficiency.--For
purposes of [section 6015(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 * * * bears to the net amount of
all items taken into account in computing the
deficiency.
* * * * * * *
(3) Allocation Of Items Giving Rise To
The Deficiency.--For purpose of * * * [section
6015(c)]--
(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 item
otherwise allocable to an individual
under subparagraph (A) shall be
allocated to the other individual
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