- 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 hadPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011