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Mr. Ohrman. In addition, McConnell concluded that petitioner had
reason to know of at least some of the distributions from the
Dean Witter account.
OPINION
Generally, married taxpayers may elect to file a joint
Federal income tax return. Sec. 6013(a). After making the
election, each spouse is jointly and severally liable for the
entire tax due for that taxable year. Sec. 6013(d)(3). A spouse
(requesting spouse) may, however, seek relief from joint and
several liability by following procedures established in
section 6015. Sec. 6015(a). A requesting spouse may request
relief from liability under section 6015(b) or, if eligible, may
allocate liability according to provisions under section 6015(c).
Sec. 6015(a). If relief is not available under section 6015(b)
or (c), an individual may seek equitable relief under section
6015(f).
Section 6015(b) Analysis
Section 6015(b) provides, in pertinent part, as follows:
SEC. 6015(b). Procedures For Relief From
Liability Applicable to All Joint Filers.--
(1) In general.–-Under procedures prescribed
by the Secretary, if–-
(A) a joint return has been made for a
taxable year;
(B) on such return there is an
understatement of tax attributable to
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