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spouse relief. Petitioner filed a timely petition and amended
petition with the Court requesting relief for the taxable year at
issue. Respondent notified Mrs. Parker who filed a notice of
intervention.
As a general rule, spouses filing a joint Federal income tax
return are jointly and severally liable for all taxes due. Sec.
6013(d)(3). However, an exception to such joint and several
liability exists for spouses able to satisfy the statutory
requirements for relief.
The Internal Revenue Service Restructuring & Reform Act of
1998, Pub. L. 105-206, sec. 3201(a), 112 Stat. 734, expanded the
relief previously available to joint filers by enacting section
6015. Section 6015 authorizes three avenues of relief from
section 6013(d)(3) joint and several liability: (1) Section
6015(b)(1) allows a spouse to escape completely joint and several
liability; (2) section 6015(b)(2) and (c) allow a spouse to elect
limited liability through relief from a portion of the
understatement or deficiency; and (3) section 6015(f) confers
upon the Secretary discretion to grant equitable relief in
situations where relief is unavailable under section 6015(b) or
(c).
Section 6015 provides, in pertinent part, as follows:
SEC. 6015. RELIEF FROM JOINT AND SEVERAL LIABILITY ON JOINT
RETURN.
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