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which relief is sought. Sec. 6015(b)(1)(D) and (c)(1); see H.
Conf. Rept. 105-599, at 252-254 (1998), 1998-3 C.B. 747, 1006-
1008. If relief is not available under either section 6015(b) or
(c), an individual may seek equitable relief under section
6015(f), which may be granted by the Commissioner in his
discretion.
In this case petitioner contends that she is entitled to
full relief from liability under section 6015(b) or (f).
Our jurisdiction to review petitioner’s request for relief
is conferred by section 6015(e), which allows a spouse who has
requested relief from joint and several liability to contest the
Commissioner’s denial of relief by filing a timely petition in
this Court. We address petitioner’s request under subsections
(b) and (f) of section 6015 in turn.
A. Section 6015(b)
Section 6015(b)(1) authorizes respondent to grant relief
from joint and several liability if the taxpayer satisfies each
requirement of subparagraphs (A) through (E). Section 6015(b)(1)
provides:
SEC. 6015(b). Procedures For Relief From Liability
Applicable to All Joint Filers.--
(1) In general.--Under procedures prescribed by
the Secretary, if--
(A) a joint return has been made for a
taxable year;
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