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joint and several liability as to each spouse under section
6013(a). See Travers v. Commissioner, T.C. Memo. 1982-88.
Section 6015, however, may relieve the requesting spouse of a
liability for tax attributable to an understatement of tax.6
Sec. 6015(b). Here, the understatements are attributable each
year to the disallowed Schedule C deductions and cost of goods
sold. Those disallowed amounts increased petitioners’ income tax
liabilities, of which the self-employment tax liabilities are
only a part. With this in mind, we turn to the provisions of
section 6015.
A requesting spouse may elect relief from joint and several
liability under section 6015.7 There are three types of relief
available: (1) Section 6015(b)(1) provides full relief from
joint and several liability; (2) section 6015(c) provides
separate tax liability available to divorced or separated
taxpayers;8 and (3) section 6015(f) provides equitable relief
6 An understatement is the “excess of the amount of tax required
to be shown on the return for the taxable year, over the amount
of tax imposed which is shown on the return”. Secs. 6015(b)(3),
6662(d)(2)(A).
7 Sec. 6015 applies to any liability for tax arising before July
22, 1998, but remaining unpaid as of that date. H. Conf. Rept.
105-599, at 255 (1998), 1998-3 C.B. 747, 1009. Mrs. Haggart’s
tax liabilities arose in 1996 and 1997, and remain unpaid.
8 Relief under sec. 6015(c) is available if the requesting
spouse is no longer married to, is legally separated from, or is
not living in the same household with the nonrequesting spouse at
the time the election is filed. Sec. 6015(c)(3)(A)(i). Mrs.
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