Yvonne E. Thurner - Page 10

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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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