- 4 - On July 15, 1999, intervenor filed his petition with this Court. Intervenor’s case was subsequently dismissed for lack of jurisdiction on the ground that the filing fee was not paid. Intervenor has filed a notice of intervention in this proceeding and objects to petitioner’s being relieved of liability under section 6015. Discussion Petitioner does not dispute the revised deficiency amount for 1993 or that the return for that year was not timely filed. Both petitioner and respondent agree that petitioner is entitled to relief under section 6015(c).2 On the basis of this agreement, respondent has calculated that petitioner and intervenor are jointly liable for $654 of the revised 1993 deficiency and that intervenor is solely liable for the remaining $2,209. Respondent has also calculated that petitioner and intervenor are jointly liable for $125 of the revised addition to tax and that intervenor is solely liable for the remaining $421 of the addition to tax. Respondent’s calculations are based on the application of section 6015(d)(3)(B), which generally provides that, for purposes of determining the proper allocation of a deficiency under section 6015(c), items giving rise to a deficiency that are allocable to the nonrequesting spouse must 2Petitioner does not argue that she is entitled to relief from joint and several liability under either section 6015(b) or (f).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011