- 13 - Section 6015(f) provides a joint filer an additional alternative for relief from joint and several liability, at the discretion of the Secretary. Petitioners ask the Court to find that Barbara is entitled to section 6015 relief with respect to the deficiencies (and interest), alternatively, under subsection (b) (relief applicable to all joint filers), (c) (limited liability for taxpayers no longer married, legally separated, or living apart), or (f) (discretionary relief) of section 6015. Respondent denies that Barbara is entitled to relief under any provision of section 6015. Except as otherwise provided in section 6015, petitioners bear the burden of proof. See Rule 142(a). II. Relief Under Section 6015(b)(1) A. Statutory Language Section 6015(b)(1) provides: SEC. 6015(b). Procedures for Relief From Liability Applicable to All Joint Filers.-- (1) In general.--Under procedures prescribed by the Secretary, if-- (A) a joint return has been made for a taxable year; (B) on such return there is an understatement of tax attributable to erroneous items of 1 individual filing the joint return; (C) the other individual filing the joint return establishes that in signing the return he or shePage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011