Gwendolyn A. Ewing - Page 12




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                    The conference agreement follows the Senate                       
               amendment with respect to deficiencies of a taxpayer                   
               who is no longer married to, is legally separated from,                
               or has been living apart for at least 12 months from                   
               the person with whom the taxpayer originally filed the                 
               joint return.  The conference agreement also includes                  
               the provision in the House bill expanding the                          
               circumstances in which innocent spouse relief is                       
               available.  Taxpayers, whether or not eligible to make                 
               the separate liability election, may be granted                        
               innocent spouse relief where appropriate.  In addition,                
               the conference agreement authorizes the Secretary to                   
               provide equitable relief in appropriate situations.                    
               The conference agreement follows the House bill and the                
               Senate amendment in establishing jurisdiction in the                   
               Tax Court over disputes arising in this area.  [H.                     
               Conf. Rept. 105-599, supra at 251, 1998-3 C.B. at 1005;                
               emphasis added.]                                                       
          The language in the conference report indicates that the                    
          reference to disputes arising in “this area” was intended to                
          encompass claims for relief arising under section 6015(b), (c),             
          and (f).  The reference to our jurisdiction comes directly after            
          the conference report discussed the Senate amendment (relating to           
          section 6015(c)), the House bill (relating to section 6015(b)),             
          and the conference agreement’s new provision authorizing                    
          equitable relief in appropriate situations (relating to section             
          6015(f)).  The conference report then states that it follows the            
          House bill and Senate amendment in establishing jurisdiction in             
          this Court over disputes arising in “this area”.8  Additionally,            


               8The General Explanation of Tax Legislation Enacted in 1998            
          prepared by the Staff of the Joint Committee on Taxation states:            
                    The provision establishes three procedures for                    
               limiting the portion of a joint and several liability                  
                                                             (continued...)           





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