- 5 - On August 10, 2000, respondent issued a Notice of Determination Concerning Relief from Joint and Several Liability Under Section 6015, determining that petitioner was not entitled to relief under section 6015(f). On September 25 and October 30, 2000, petitioner filed a timely petition and an amended petition, respectively, with the Court requesting relief for the years at issue. Respondent notified Mr. August of the petitions. OPINION Petitioner requests that the Court grant her relief from these taxes under section 6015(f). Respondent argues that he did not abuse his discretion in denying petitioner’s claim for relief under section 6015(f) because petitioner presented no evidence supporting her claim, and, therefore, petitioner did not qualify for relief under the criteria provided in Rev. Proc. 2000-15, 2000-1 C.B. 447 (the revenue procedure). 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 provides exceptions to this general rule in certain circumstances. Butler v. Commissioner, supra. Section 6015(f) provides: SEC. 6015(f). Equitable Relief.--Under procedures prescribed by the Secretary, if--Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011