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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).
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Last modified: May 25, 2011