Jeanne M. Trent - Page 6

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          determined whether petitioner had any additional Federal taxes              
          due.  The three overpayments that respondent withheld to offset             
          petitioner’s liability included earned income credits for 1999,             
          2000, and 2001.                                                             
               Generally, married taxpayers may elect to file a joint                 
          Federal income tax return.  Sec. 6013(a).  After making the                 
          election, each spouse is jointly and severally liable for the               
          entire tax due for that taxable year.  Sec. 6013(d)(3).  A spouse           
          (requesting spouse) may, however, seek relief from joint and                
          several liability by following procedures established in section            
          6015.  Sec. 6015(a).  Section 6015 replaced prior section 6013(e)           
          and was intended to expand relief available to joint filers.  See           
          Internal Revenue Service Restructuring and Reform Act of 1998               
          (RRA 1998), Pub. L. 105-206, sec. 3201, 112 Stat. 685, 734.  The            
          RRA 1998 gave section 6015 retroactive effect in that it was made           
          applicable to any liability for tax arising after July 22, 1998,            
          and to any liability for tax arising on or before such date that            
          remained unpaid as of July 22, 1998.  RRA 1998 sec. 3201(g)(1),             
          112 Stat. 740; Vetrano v. Commissioner, 116 T.C. 272, 277 (2001).           
          A requesting spouse may request relief from liability under                 
          section 6015(b) or, if eligible, may allocate liability according           
          to provisions in section 6015(c).  Sec. 6015(a).  In addition, if           

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