Ranie M. Raymond - Page 9




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               B.  Relief Under Section 6015(f)                                       
               On its face, section 6015(f) does not require that a joint             
          return be filed in order for equitable relief to be granted under           
          that section.7  As directed by section 6015(f), the Commissioner            

               6(...continued)                                                        
                    the liability for tax * * * for such taxable                      
                    year to the extent such liability is                              
                    attributable to such understatement.                              
                    [Emphasis added.]                                                 
          Sec. 6015(c) provides:                                                      
                    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).  [Emphasis                       
                    added.]                                                           
               7  Sec. 6015(f) provides:                                              
                    SEC. 6015(f).  Equitable Relief.--Under procedures                
               prescribed by the Secretary, if--                                      
                         (1) taking into account all the facts                        
                    and circumstances, it is inequitable to hold                      
                    the individual liable for any unpaid tax or                       
                    any deficiency (or any portion of either);                        
                    and                                                               
                         (2) relief is not available to such                          
                    individual under subsection (b) or (c),                           
                                                             (continued...)           




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