Ruthe G. Ohrman - Page 14

                                       - 14 -                                         
          Mr. Ohrman.  In addition, McConnell concluded that petitioner had           
          reason to know of at least some of the distributions from the               
          Dean Witter account.                                                        
               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               
          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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