Guy Nathaniel Gay, Jr., Petitioner and Kimberly S. Gibson, Intervenor - Page 7

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               Spouses who file a joint Federal income tax return generally           
          are jointly and severally liable for the payment of the tax shown           
          on the return or found to be owing.  Sec. 6013(d)(3); Cheshire v.           
          Commissioner, 115 T.C. 183, 188 (2000), affd. 282 F.3d 326 (5th             
          Cir. 2002).  However, relief from joint and several liability is            
          available to certain taxpayers under section 6015.  There are               
          three avenues for relief under this section--section 6015(b),               
          (c), and (f).                                                               
               The first avenue for relief is section 6015(b).  This                  
          provision provides full or apportioned relief from joint and                
          several liability for an understatement of tax on a joint return            
          if, among other requirements, the taxpayer requesting relief                
          “establishes that in signing the return he or she did not know,             
          and had no reason to know” of the relevant portion of the                   
          understatement of tax on the return.  Sec. 6015(b)(1)(C), (b)(2).           
          Generally, the spouse seeking relief has reason to know of the              
          understatement if he has reason to know of the transaction that             
          gave rise to the understatement.  Jonson v. Commissioner, 118               
          T.C. 106, 115 (2002).                                                       
               The second avenue for relief is section 6015(c).  This                 
          provision provides proportionate relief through allocation of a             
          deficiency between individuals who filed a joint return and who             
          are no longer married, who are legally separated, or who have               
          been living apart for the preceding 12 months.  Among other                 






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