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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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Last modified: May 25, 2011