- 23 - to his financial affairs. Barbara was fully aware of the Vulcan investment, of the tax benefits to be derived, and of the risk that those benefits might be challenged by the IRS on audit. Under the foregoing circumstances, we find that it would not be inequitable to hold Barbara liable for the deficiencies arising out of the Vulcan investment. C. Conclusion Barbara has failed to satisfy the requirements of either section 6015(b)(1)(C) or (D). III. Relief Under Section 6015(c) A. Statutory Language Section 6015(c) provides in pertinent part: SEC. 6015(c). Procedures To Limit Liability for Taxpayers No Longer Married or Taxpayers Legally Separated or Not Living Together.-- (1) In general.--Except as provided in this subsection, if an individual who has made a joint return for any taxable year elects the application of this subsection, the individual’s liability for any deficiency which is assessed with respect to the return shall not exceed the portion of such deficiency properly allocable to the individual under subsection (d). * * * * * * * (3) Election.-- (A) Individuals eligible to make election.-- (i) In general.--An individual shall only be eligible to elect the application of this subsection if--Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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