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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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