- 4 -
On September 18, 2000, respondent determined petitioner was
not entitled to section 6015 relief because she had actual
knowledge of the income that caused the understatement of tax,
and it would not be inequitable to hold petitioner liable for the
tax. By notice dated September 25, 2000, respondent informed
petitioner of his determination.
On July 12, 2001, petitioner, while residing in Silver
Springs, Florida, filed her petition with this Court, in which
she contends that she is entitled to section 6015 relief. On
September 10, 2001, respondent gave notice of petitioner’s
contention to Mr. Tice.
OPINION
Respondent contends that petitioner is not entitled to
section 6015 relief because she knew the nature of Mr. Tice’s
work with TDI, the amount he was paid, and that such compensation
was not reported on their joint return. Respondent contends
that, but for the omission of income relating to TDI, petitioner
and Mr. Tice would not have qualified for a $961 earned income
credit.
Generally, taxpayers filing joint Federal income tax returns
are jointly and severally liable for all taxes due. Sec.
6013(d)(3). In limited situations, however, taxpayers may be
relieved of joint liability. Sec. 6015. Petitioner is not
entitled to relief pursuant to section 6015(b) or (c), if she had
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011