Rosalinda E. Alt - Page 17




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               B.   Relief Under Section 6015(c)                                        
               We conclude that petitioner is not entitled to relief under              
          section 6015(c) for taxable years 1982 to 1988.  At the time                  
          petitioner filed her election for relief under section 6015,                  
          petitioner and Dr. Alt were married, had not separated from one               
          another, and had remained members of the same household during                
          the 12-month period preceding the filing of the election by                   
          petitioner.9  Sec. 6015(c)(3)(A)(i).10                                        
               C.   Relief Under Section 6015(f)                                        
               Respondent argues that he did not abuse his discretion in                
          denying petitioner equitable relief under section 6015(f).11                  


               9  We note that Dr. Alt was released from prison some time               
          earlier than 1995, and petitioner filed her election for relief               
          under sec. 6015 on Apr. 14, 2000.                                             
               10  Sec. 6015(c)(3)(A)(i) grants relief to individuals only              
          if:                                                                           
                    (I) at the time such election is filed, such                        
               individual is no longer married to, or is legally                        
               separated from, the individual with whom such                            
               individual filed the joint return to which the election                  
               relates; or                                                              
                    (II) such individual was not a member of the same                   
               household as the individual with whom such joint return                  
               was filed at any time during the 12-month period ending                  
               on the date such election is filed.                                      
               11  Sec. 6015(f) provides:                                               
                    SEC. 6015(f).  Equitable Relief.--Under procedures                  
               prescribed by the Secretary, if--                                        
                         (1) taking into account all the facts and                      
                                                               (continued...)           





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