- 4 - Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3201, 112 Stat. 685, 734. The provision provides relief from joint and several liability for certain taxpayers who file a joint Federal income tax return. In general terms, there are three avenues of relief under section 6015: Section 6015(b) may provide relief with respect to certain erroneous items on the return, section 6015(c) may provide for a separation of liability for separated taxpayers, and section 6015(f) may provide equitable relief for taxpayers who otherwise do not qualify for relief under either of the other two provisions. As a general rule, taxpayers who qualify for relief under section 6015(b) or (f)--but not section 6015(c)--are entitled to a refund or credit attributable to the application of section 6015. Sec. 6015(g)(1), (3). After a taxpayer requests relief under section 6015, the taxpayer may petition this Court for a review of respondent’s subsequent determination. Sec. 6015(e)(1)(A). Our jurisdiction in cases brought under section 6015(e)(1) encompasses a review of respondent’s determination with respect to all relief afforded by section 6015. Fernandez v. Commissioner, 114 T.C. 324, 331 (2000). Thus, we have jurisdiction to review respondent’s determination that no refund is due petitioner pursuant to section 6015(g)(3). However, we note that we have jurisdiction with respect to only a portion of the tax liability at issue in this case. Overpayments which are credited to another year’s taxPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011