John A. Rowe and Donna L. Rowe - Page 9




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          grossly erroneous items of the other spouse; (3) in signing the             
          return, the spouse seeking relief did not know, and had no reason           
          to know, of the substantial understatement; and (4) under the               
          circumstances it would be inequitable to hold the spouse seeking            
          relief liable for the substantial understatement.                           
               Relief under section 6013(e) was difficult for many                    
          taxpayers to obtain.  In 1998, Congress repealed section 6013(e)            
          and enacted section 6015 in order to make relief from joint                 
          liability more accessible.  Internal Revenue Service                        
          Restructuring and Reform Act of 1998, Pub. L. 105-206, sec.                 
          3201(a), 112 Stat. 734; H. Conf. Rept. 105-599, at 249 (1998),              
          1998-3 C.B. 747, 1003.  Section 6015 provides three avenues of              
          relief from joint and several liability:  (1) Section 6015(b)(1)            
          (which is similar to former section 6013(e)) allows a spouse to             
          escape joint and several liability; (2) section 6015(b)(2) and              
          (c) allows a spouse to be relieved from a portion of the                    
          understatement or deficiency; and (3) section 6015(f) confers               
          upon the Secretary discretion to grant equitable relief in                  
          situations where relief is unavailable under section 6015(b) or             
          (c).  Section 6015 generally applies to any liability for tax               
          arising after July 22, 1998, and any liability for tax arising on           
          or before July 22, 1998, that remains unpaid as of such date.  H.           
          Conf. Rept. 105-599, supra at 251, 1998-3 C.B. at 1005.                     








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