William G. Applegate - Page 8

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          supra; King v. Commissioner, supra; Ockrant v. Commissioner,                
          supra; Worth v. Commissioner, supra.  Respondent's determination            
          disallowing petitioners' deduction for unreimbursed employee                
          business expenses is sustained.                                             
          2.  Relief From Joint and Several Liability Under Section 6015              
               Generally, married taxpayers may elect to file a joint                 
          Federal income tax return.  Sec. 6013(a).  After making the                 
          election, each spouse is jointly and severally liable for the               
          entire tax due.  Sec. 6013(d)(3).  A spouse may seek relief from            
          joint and several liability under section 6015.  A spouse may               
          qualify for relief from liability under section 6015(b), or if              
          eligible, may allocate liability under section 6015(c).  In                 
          addition, if relief is not available under section 6015(b) or               
          (c), an individual may seek equitable relief under section                  
          6015(f).  Fernandez v. Commissioner, 114 T.C. 324, 329-331                  
          (2000); Butler v. Commissioner, 114 T.C. 276, 287-292 (2000).               
          The Court's review is not limited to the Commissioner's                     
          administrative record.  Ewing v. Commissioner, 122 T.C. 32, 44              
          (2004).                                                                     
               Except as otherwise provided in section 6015, the taxpayer             
          bears the burden of proof.  Rule 142(a); Alt v. Commissioner, 119           
          T.C. 306, 311 (2002), affd. 101 Fed. Appx. 34 (6th Cir. 2004).              
               Ms. Wang seeks relief from liability under section 6015 with           
          respect to respondent's adjustments to the 1999 return for the              






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