- 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011