- 10 - 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 underPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011