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respect to any liability for tax remaining unpaid as of July 22,
1998. See RRA 1998 sec. 3201(g)(1), 112 Stat. 740.5
Section 6015 is more accessible than former section 6013(e).
See Cheshire v. Commissioner, supra at 189; H. Conf. Rept. 105-
599, at 249 (1998), 1998-3 C.B. 747, 1003. Section 6015 provides
three avenues of relief from joint and several liability. First,
section 6015(b)(1) (which is similar to former section 6013(e))
allows a spouse to escape joint and several liability. Section
6015(b)(2) also allows a spouse to be relieved from a portion of
the understatement. Second, section 6015(c) generally provides
for an allocation of liability for a deficiency as if the spouses
had filed separate returns. Third, section 6015(f) confers upon
the Secretary discretion to grant equitable relief in situations
where relief is unavailable under section 6015(b) or (c). See
Cheshire v. Commissioner, supra; Mora v. Commissioner, 117 T.C.
279, 285 (2001).
In the instant case, petitioner requests relief under
section 6015(b), (c), and (f) with respect to the tax liabilities
5Sec. 3201(g)(1) of the Internal Revenue Service
Restructuring and Reform Act of 1998 (RRA 1998), Pub. L. 105-206,
112 Stat. 740, provides that sec. 6015 “shall apply to any
liability for tax arising after the date of the enactment of this
Act and any liability for tax arising on or before such date but
remaining unpaid as of such date.” RRA 1998 sec. 3201(g)(2)
provides that the 2-year period of limitations for filing an
election in sec. 6015(b)(1)(E) or (c)(3)(B) “shall not expire
before the date which is 2 years after the date of the first
collection activity after the date of the enactment of this Act.”
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