Rosalinda E. Alt - Page 10




                                        - 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.                                                      








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