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provides relief with respect to understatements of tax
attributable to certain erroneous items on the return; (2)
section 6015(c) provides relief for a portion of an
understatement of tax for taxpayers who are separated or
divorced; and (3) section 6015(f) more broadly confers on the
Secretary discretion to grant equitable relief for taxpayers who
otherwise do not qualify for relief under section 6015(b) or (c).
Petitioner was not eligible for relief under section 6015(b)
or (c). Therefore, her petition falls under the equitable relief
provision in section 6015(f). Section 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),
the Secretary may relieve such individual of such liability.
As directed by section 6015(f), the Commissioner has prescribed
guidelines in Rev. Proc. 2000-15, 2000-1 C.B. 447, 448, that the
Commissioner will consider in determining whether an individual
qualifies for relief under section 6015(f). Rev. Proc. 2000-15,
sec. 4.01, lists seven threshold conditions which must be
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Last modified: May 25, 2011