- 17 -
to the tax laws or legal consequences of the operative facts is
not required. King v. Commissioner, supra, at 204; Cheshire v.
Commissioner, supra, at 195.
C. Section 6015(f)
Section 6015(f) permits the Secretary to relieve a spouse of
liability if, taking into account all the facts and
circumstances, it is inequitable to hold the spouse liable for
any unpaid tax or deficiency (or any portion of either) and
relief is not otherwise available under section 6015(b) or (c).
Sec. 6015(f); Cheshire v. Commissioner, supra at 197.
Respondent’s denial of equitable relief is reviewed under an
abuse of discretion standard. Cheshire v. Commissioner, supra at
198; Butler v. Commissioner, 114 T.C. at 292. This is a question
of fact. Cheshire v. Commissioner, supra.
On the basis of the circumstances of this case, we initially
consider the merits of petitioner’s claims for relief with
respect to income and deduction items under section 6015(c). The
parties agree that petitioner made a valid election under section
6015(c), she was no longer married to Mr. Rowe at the time of the
election, and petitioner and Mr. Rowe filed joint returns for the
years in issue. To the extent petitioner fails to qualify for
relief under subsection (c), we address her claim for relief
under section 6015(b). To the extent petitioner fails to qualify
for relief under section 6015(b) or (c), we address her claim for
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