- 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