-11- section 6015(b), a taxpayer must show that it is inequitable to be held liable for tax due on a joint return. See sec. 6015(b)(1)(D). Under section 6015(f), the Secretary may grant relief from joint liability if it is inequitable to hold the individual liable for any unpaid tax or deficiency. Charlton was present at trial. Thus, he had the opportunity to present evidence relating to whether or to what extent it was equitable to hold Hawthorne jointly liable for tax. He did not establish that it was an abuse of discretion for respondent to relieve Hawthorne from joint liability to the extent determined by respondent under section 6015(f). Based on the Form 886A and the trial record in these cases, we conclude that respondent’s grant of relief to Hawthorne under section 6015(f) was not an abuse of discretion. Thus, we sustain that determination. For the foregoing reasons, Decision will be entered consistent with agreed computations submitted under Rule 155 by respondent and Hawthorne in docket No. 11861-98 and consistent withPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011