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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
procedure.
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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