Cynthia Emery Weight - Page 7

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            tax shown on the return or otherwise determined to be due.  Sec.                            
            6013(d)(3); Cheshire v. Commissioner, 115 T.C. 183, 188 (2000),                             
            affd. 282 F.3d 326 (5th Cir. 2002).  In certain situations and                              
            subject to a variety of conditions, section 6015 provides for                               
            relief from the joint and several liability that arises from a                              
            joint return.                                                                               
                  If a taxpayer does not qualify for relief under subsection                            
            (b) or subsection (c) of section 6015, then under procedures                                
            prescribed in Rev. Proc. 2000-15, 2000-1 C.B. 447, the                                      
            Commissioner has discretionary authority to relieve the taxpayer                            
            from joint and several liability for a particular year if,                                  
            “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)” for that year.  Sec.                             
            6015(f).  Some of the factors the Commissioner will take into                               
            account in considering a taxpayer’s claim for section 6015(f)                               
            relief are specifically set forth in the above-referenced revenue                           
                 In this case, petitioner relies upon section 6015(f) in                               
            support of her claim for relief from the balance of the unpaid                              
            income tax liability arising from the joint return.  At trial,                              
            petitioner indicated that the outstanding 1996 liability roughly                            
            approximated the “late filing penalty” imposed pursuant to                                  
            section 6651(a)(1) and, for the most part, limited her claim to                             

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