Michael Vetrano and Patricia Vetrano - Page 16




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             Opinion is whether Mrs. Vetrano is eligible for relief                   
             under section 6015(b).  Section 6015(b) is applicable to                 
             all joint filers who elect relief under that subsection and              
             who establish that they meet the four other requirements                 
             set forth therein.  The other requirements are similar to                
             the requirements that were prescribed by former section                  
             6013(e).  See Butler v. Commissioner, 114 T.C. at 283.                   
                  One of those requirements is that the individual                    
             seeking relief under section 6015(b) establish "that in                  
             signing the return he or she did not know, and had no                    
             reason to know" that there was an understatement                         
             attributable to the erroneous items of the other spouse.                 
             Sec. 6015(b)(1)(C); see Cheshire v. Commissioner, 115 T.C.               
             183, 192-193 (2000).  Notwithstanding the individual's                   
             knowledge or reason to know of some part of the                          
             understatement, section 6015(b)(2) permits the individual                
             to qualify for relief as to the remainder of the                         
             understatement, if the individual establishes that in                    
             signing the return he or she did not know, and had no                    
             reason to know, the extent of the understatement.  See sec.              
             6015(b).  In that case, the individual will be relieved of               
             liability for tax "to the extent that such liability is                  
             attributable to the portion of such understatement of which              








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