- 6 -
spouse did not know, and had no reason to know, of the
substantial understatement; and (3) under the circumstances, it
would be inequitable to hold the spouse liable for the tax
liability relating to the substantial understatement.
Based on Congress’s conclusion that the provisions of
section 6013(e) granting relief from joint liability were
inadequate, S. Rept. 105-174 at 55 (1998), 1998-3 C.B. 537, 591,
and to make relief from joint liability more accessible, H. Conf.
Rept. 105-599, at 249 (1998), 1998-3 C.B. 747, 1003, Congress in
1998 enacted section 6015. Internal Revenue Service
Restructuring and Reform Act of 1998 (RRA 1998), Pub. L. 105-206,
sec. 3201(a), 112 Stat. 734.
Section 6015 applies to tax liabilities arising after
July 22, 1998, and to tax liabilities arising on or before
July 22, 1998, but remaining unpaid as of such date. RRA 1998
sec. 3201(g), 112 Stat. 740.
Respondent argues that our review of petitioner’s claim for
relief from joint liability under section 6015 is limited to $150
(the amount remaining unpaid as of July 22, 1998, the effective
date of section 6015).
Section 6015 has been applied to a taxpayer’s entire tax
liability where the liability arose before the effective date of
section 6015 but where the entire liability remained unpaid on
July 22, 1998. See Vetrano v. Commissioner, 116 T.C. 272 (2001);
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011