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ability to rebuild the residence. Petitioner did not present
evidence regarding her inability to pay her reasonable basic
living expenses, see sec. 301.6343-1(b)(4)(i), Proced. & Admin.
Regs., or any other unique circumstances which might lead us to
conclude that she will suffer economic hardship if, after
application of section 6015(c), she remains jointly and severally
liable for any remaining portions of the liabilities for 1982,
1983, and 1984. We hold that respondent did not abuse his
discretion in deciding that it is not inequitable to hold
petitioner jointly and severally liable for any remaining
portions of the joint income tax liabilities for 1982, 1983, and
1984. Petitioner is not entitled to relief for those liabilities
under section 6015(f).
B. Underpayments in 1988 and 1989
Petitioner claims relief under section 6015(b), (c), or (f)
for her joint and several tax liabilities for 1988 and 1989.
Subsections (b) and (c) of section 6015 apply only in the case of
“an understatement of tax” or “any deficiency” in tax and do not
apply in the case of underpayments of taxes reported on joint tax
returns. Sec. 6015(b)(1)(B) and (c)(1); see also Block v.
Commissioner, 120 T.C. 62, 66 (2003); Ewing v. Commissioner, 118
T.C. 494, 497, 498 n.4 (2002). We hold that petitioner is not
entitled to relief under section 6015(b) or (c) for her 1988 and
1989 tax liabilities.
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