Barbara Rooks - Page 6

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          respect to liability for deficiencies.  Sec. 6015(c)(1).  In                
          general terms, and for purposes of this case, both an                       
          “understatement” and a “deficiency” are equal to the amount of              
          tax required to be shown on a return less the amount of tax                 
          actually shown on the return.  Secs. 6015(b)(3), 6662(d)(2)(A),             
          6211(a).  The unpaid tax liabilities in this case result from               
          amounts shown as due on the returns filed by petitioner and Mr.             
          Rooks.  These underpayments have been assessed by respondent.               
          Because respondent does not assert that the amounts of tax shown            
          on petitioner’s returns as filed (and as reduced by the amended             
          returns) were less than the amounts required to be shown thereon,           
          there is neither an understatement nor a deficiency in this case,           
          making section 6015(b) and (c) inapplicable.                                
               The remaining avenue for relief under section 6015 is the              
          equitable relief which may be afforded by section 6015(f).  This            
          relief is available to taxpayers who are not otherwise entitled             
          to section 6015 relief if, taking into account all the facts and            
          circumstances, it is inequitable to hold the taxpayer liable for            
          any unpaid tax or deficiency (or portion thereof).  Sec.                    
          6015(f)(1) and (2).  Section 6015(f) relief is available to                 
          petitioner--because that provision applies to any unpaid tax                
          liability--and this Court may review respondent’s denial of such            
          relief.  Ewing v. Commissioner, 118 T.C. 494 (2002).                        
               Equitable relief under section 6015(f) is discretionary, and           






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