- 3 - underpayment of 1994 income taxes at issue herein, as well as for an unpaid income tax deficiency for 1992. In the Final Notice of Determination dated July 24, 2002, respondent granted partial relief (50 percent) to petitioner from joint and several liability for the tax liability on the 1994 joint return. After petitioner filed the petition in this case, the administrative file was forwarded to the San Diego Appeals Office for consideration. The Appeals Officer recommended that petitioner be granted full relief from joint and several liability for the underpayment as requested, rather than only 50 percent relief as previously determined. Intervenor filed his Notice of Intervention on December 31, 2002. He disputes that petitioner is entitled to full equitable relief from joint liability instead of the 50 percent relief previously granted by respondent in the final determination letter upon which petitioner’s case is based. In this case, we are concerned only with section 6015(f). Section 6015(f) provides in pertinent part: 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); * * * * * * *Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011