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of material fact, and factual inferences will be read in a manner
most favorable to the party opposing summary judgment. See
Dahlstrom v. Commissioner, 85 T.C. 812, 821 (1985); Jacklin v.
Commissioner, 79 T.C. 340, 344 (1982).
A. Section 6015
Spouses filing joint Federal income tax returns generally
are jointly and severally liable for all taxes due. Sec.
6013(d)(3). However, under certain circumstances, section 6015
provides that a spouse may be relieved from joint and several
liability on a joint return.
Section 6015 was enacted as part of the Internal Revenue
Service Restructuring and Reform Act of 1998 (RRA 1998), Pub. L.
105-206, sec. 3201(a), 112 Stat. 685, 734. Section 6015 applies
to any liability for tax arising after July 22, 1998, and to any
liability for tax arising on or before July 22, 1998, but
remaining unpaid as of such date. RRA 1998 sec. 3201(g), 112
Stat. 740. Section 6015 is not applicable if the tax was paid in
full on or before July 22, 1998. Washington v. Commissioner, 120
T.C. 137, 155 (2003).
Broadly stated, section 6015(b) provides procedures for
relief from liability applicable to all joint filers; section
6015(c) provides procedures to limit liability for taxpayers who
filed a joint return but are no longer married, are legally
separated, or are not living together; and section 6015(f)
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