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OPINION
In general, taxpayers filing joint Federal income tax
returns are each responsible for the accuracy of the return and
are jointly and severally liable for the full tax liability.
Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C. 276, 282
(2000). In certain circumstances, however, a taxpayer may obtain
relief from joint and several liability by satisfying the
requirements of section 6015.10
Section 6015(a)(1) provides that a spouse who has made a
joint return may elect to seek relief from joint and several
liability under section 6015(b) (dealing with relief from
liability for an understatement of tax on a joint return).
Section 6015(a)(2) provides that a spouse who is eligible to do
so may elect to limit that spouse’s liability for any deficiency
with respect to a joint return under section 6015(c). Relief
from joint and several liability under section 6015(b) or (c) is
available only with respect to a deficiency for the year for
9(...continued)
treated the application as a request for relief under sec.
6015(b), (c), and (f) and denied relief under each subsection in
his preliminary and final determination letters. Petitioner does
not dispute respondent’s determination with respect to his denial
of sec. 6015(c) relief.
10Sec. 6015 applies to tax liabilities arising after July
22, 1998, and to tax liabilities arising on or before July 22,
1998, that remain unpaid as of such date. Internal Revenue
Service Restructuring and Reform Act of 1998, Pub. L. 105-206,
sec. 3201(g), 112 Stat. 740.
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