- 10 - On March 2, 2001, petitioner filed a petition with this Court to dispute respondent’s denial of relief under section 6015 for taxable years 1982 through 1989. OPINION Generally, spouses filing a joint tax return are each fully responsible for the accuracy of their return and for the full tax liability. Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C. 276, 282 (2000). Section 6015, however, provides various means by which a spouse can be relieved of this joint and several obligation. Petitioner makes her claim for such relief under section 6015(b), (c), and (f). Except as otherwise provided in section 6015, petitioner bears the burden of proof. Rule 142(a). I. Jurisdiction Our jurisdiction for taxable years 1982 to 1989 is dependent on section 6015(e) because petitioner’s claim for relief was made in a “stand alone” petition. Ewing v. Commissioner, 118 T.C. 494, 497 (2002). Respondent treated petitioner’s request for relief under section 6015 as an election under section 6015(b), (c), and (f). Further, petitioner timely filed her petition with the Court for taxable years 1982 through 1988. We hold that we have jurisdiction under section 6015(e) to review the denial of petitioner’s request for relief under section 6015 for taxable years 1982 through 1988.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011