Evelyn M. Martin - Page 11




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          rental; $99,838 and $36,422 for insurance sales commission                  
          expenses for 1986 and 1987, respectively.                                   
               Section 6015 provides, in certain circumstances, for relief            
          from joint liability for tax, interest, penalties, and other                
          amounts arising from a joint Federal income tax return.  See sec.           
          6015(a), (b), and (c).1   Section 6015(a) permits taxpayers to              
          seek relief under section 6015(b) if they filed a joint return              
          and, if eligible, under section 6015(c).  Section 6015(c), in               
          pertinent part, provides for relief for certain joint filers, as            
          follows:                                                                    
                    (c) Procedures to limit liability for taxpayers no                
          longer married or taxpayers legally separated                               
                    or not living together.                                           
               (1) In general. Except as provided in this                             
          subsection, if an individual who has made a joint                           
          return for any taxable year elects the application of                       
          this subsection, the individual’s liability for any                         
          deficiency which is assessed with respect to the                            
          return shall not exceed the portion of such deficiency                      
          properly allocable to the individual under subsection                       
          (d).                                                                        
               (2) Burden of Proof. Except as provided in                             
          subparagraph (A)(ii) or (C) of paragraph (3), each                          
          individual who elects the application of this                               
                    subsection shall have the burden of proof with respect            
                    to establishing the portion of any deficiency allocable           
          to such individual.                                                         



               1 Sec. 6015 was added by sec. 3201(a) of the Internal                  
          Revenue Service Restructuring and Reform Act of 1998 (RRA), Pub.            
          L. 105-206, 112 Stat. 734.  Sec. 6015 is effective with respect             
          to any tax liability arising after July 22, 1998, and any tax               
          liability arising on or before July 22, 1998, that is unpaid on             
          that date.                                                                  





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