Tracy Jodette August - Page 5




                                        - 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--                                      





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