- 4 - OPINION The above findings of fact are sparse. The record in this case does not include either the tax returns for the years in issue or the notices of deficiency, and, therefore, we cannot determine the nature of the adjustments leading to the deficiencies and unpaid taxes and whether they are solely attributable or allocable to H. Smith. Section 6015 provides in pertinent part as follows: SEC. 6015. RELIEF FROM JOINT AND SEVERAL LIABILITY ON JOINT RETURN. * * * * * * * (b) Procedures For Relief From Liability Applicable to All Joint Filers.-- (1) In general.--Under procedures prescribed by the Secretary, if-– (A) a joint return has been made for a taxable year; (B) on such return there is an understatement of tax attributable to erroneous items of 1 individual filing the joint return; (C) the other individual filing the joint return establishes that in signing the return he or she did not know, and had no reason to know, that there was such understatement; (D) taking into account all the facts and circumstances, it is inequitable to hold the other individual liable for the deficiency in tax for such taxable year attributable to such understatement; andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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