- 5 -
and the joint filing status was allowed, permitting petitioner
the benefit of exemptions, itemized deductions for medical
expenses (reflected on the adjusted joint return totaling
$9,486), and expenses attributable to Ms. Morrison, her mother,
and her daughter. In addition, petitioner obtained the benefit
of itemized deductions relating to mortgage interest and real
estate taxes on the joint return of $11,734 and $2,632,
respectively. As a result of the initial audit, petitioner and
Ms. Morrison were issued a refund of $415. After discovery of
$28,146 of unreported Social Security income, respondent, during
1999, audited the 1996 joint return a second time. Respondent
determined a $3,347 deficiency based on the unreported Social
Security income. The corresponding increase to adjusted gross
income resulted in purely mathematical reductions in itemized
deductions, in the amount of $2,674.
OPINION
The issue we consider is whether petitioner is eligible for
relief from joint and several liability under subsections (b) or
(c) of section 6015.
I. Relief Under Section 6015(b)(1)
Section 6015(b)(1) provides for spousal relief from joint
and several liability if the following requirements are met:
(A) a joint return has been made for a taxable
year;
(B) on such return there is an understatement of
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011