Robert L. Beck - Page 18

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          for relief as arising under section 66(c), which provides relief            
          from income tax liability with respect to unreported community              
          income in certain circumstances.  Section 66(c) provides:                   
                    SEC. 66(c).  Spouse Relieved of Liability in                      
               Certain Other Cases.--Under regulations prescribed by                  
               the Secretary, if–-                                                    
                         (1) an individual does not file a joint                      
                    return for any taxable year,                                      
                         (2) such individual does not include in                      
                    gross income for such taxable year an item of                     
                    community income properly includible therein                      
                    which, in accordance with the rules contained                     
                    in section 879(a), would be treated as the                        
                    income of the other spouse,                                       
                         (3) the individual establishes that he                       
                    or she did not know of, and had no reason to                      
                    know of, such item of community income, and                       
                         (4) taking into account all facts and                        
                    circumstances, it is inequitable to include                       
                    such item of community income in such                             
                    individual’s gross income,                                        
               then, for purposes of this title, such item of                         
               community income shall be included in the gross income                 
               of the other spouse (and not in the gross income of the                
               individual).  Under procedures prescribed by the                       
               Secretary, if, taking into account all the facts and                   
               circumstances, it is inequitable to hold the individual                
               liable for any unpaid tax or any deficiency (or any                    
               portion of either) attributable to any item for which                  
               relief is not available under the preceding sentence,                  
               the Secretary may relieve such individual of such liability.           

          conditioned on the electing individual’s having made a joint                
          return for the year in question.  See sec. 6015(a), (b)(1)(A),              
          and (c)(1); Rev. Proc. 2000-15, 2000-5 I.R.B. 447 (Jan. 31,                 

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