- 17 - 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...)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