Lisa Marie Pierce - Page 11

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          Commissioner, 118 T.C. 106, 125 (2002); Cheshire v. Commissioner,           
          115 T.C. at 198; Butler v. Commissioner, supra.                             
               On July 17, 2002, respondent adopted regulations under                 
          section 6015.  These regulations are applicable for all elections           
          or requests for relief filed on or after July 18, 2002.  Sec.               
          1.6015-9, Income Tax Regs.  These regulations are not applicable            
          in the instant case because petitioner requested relief before              
          July 18, 2002.                                                              
          Whether Petitioner Is Entitled to Equitable Relief                          
               Section 6015(f) provides:                                              
               Equitable Relief.–-Under procedures prescribed by the                  
               Secretary, if–-                                                        
                    (1) taking into account all the facts                             
                    and circumstances, it is inequitable to hold                      
                    the individual liable for any unpaid tax or                       
                    any deficiency (or any portion of either);                        
                    and                                                               
                    (2) relief is not available to such                               
                    individual under subsection (b) or (c),                           
               the Secretary may relieve such individual of such                      
               liability.                                                             

               Because petitioner is not eligible for relief under either             
          section 6015(b) or (c), the only avenue for relief available to             
          petitioner is section 6015(f).  As directed by section 6015(f),             
          the Commissioner has prescribed guidelines in Rev. Proc. 2000-15,           
          2000-1 C.B. 447, 448, that the Commissioner will consider in                
          determining whether an individual qualifies for relief under                






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