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(Embodying Notice of Intervention) (the motion). The motion was
served on the parties. Respondent filed a notice of no
objection, and petitioner has not responded.
Discussion
We have recently issued several opinions involving claims
for relief from joint liability in which we noted significant
differences between section 6015 and the repealed section
6013(e). See Corson v. Commissioner, supra; Charlton v.
Commissioner, 114 T.C. 333 (2000); Fernandez v. Commissioner, 114
T.C. 324 (2000); Butler v. Commissioner, 114 T.C. 276 (2000).
For example, in Corson v. Commissioner, supra, we observed:
Whereas section 6013(e) had offered only a single
avenue of relief, based on a spouse's lack of knowledge
or reason to know of a substantial understatement,
section 6015 authorizes three types of relief.
Subsection (b) provides a form of relief available to
all joint filers and similar to, but less restrictive
than, that previously afforded by section 6013(e).
Subsection (c) permits a taxpayer who has divorced or
separated to elect to have his or her tax liability
calculated as if separate returns had been filed.
Subsection (f) confers discretion upon the Commissioner
to grant equitable relief, based on all facts and
circumstances, in cases where relief is unavailable
under subsection (b) or (c).
Subsections (a), (e), and (g) of section 6015
address general and procedural aspects relating to the
operation of the section and the role therein to be
played by this Court and by the Commissioner. * * *
[Id. at 359-360.]
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