Tony D. Ishizaki - Page 10




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                         and circumstances, it is inequitable to hold                 
                         the other spouse liable for the deficiency in                
                         tax for such taxable year attributable to                    
                         such substantial understatement,                             
               then the other spouse shall be relieved of liability                   
               for tax (including interest, penalties, and other                      
               amounts) for such taxable year to the extent such                      
               liability is attributable to such substantial                          
               understatement.                                                        
          The section then went on to impose an additional requirement, in            
          order for relief to be available, that the understatement exceed            
          a specified percentage of the income of the spouse who was                  
          seeking such relief.  See sec. 6013(e)(4).                                  
               B.  Present Law                                                        
               The RRA revised and expanded the relief available to joint             
          filers by striking subsection (e) from section 6013 and by                  
          promulgating in its place a new section 6015.  RRA sec. 3201(a),            
          (e)(1), 112 Stat. 734, 740.  Section 6015 was also given                    
          retroactive effect to the extent that it was made applicable to             
          any liability for tax arising after July 22, 1998, and to any               
          liability for tax arising on or before such date but remaining              
          unpaid as of July 22, 1998.  RRA sec. 3201(g)(1), 112 Stat. 740.            
               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).              





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