William G. Applegate - Page 9

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          disallowed employee business expenses.  She does not qualify for            
          relief under section 6015(c) because she is still married to Mr.            
          Applegate.  See sec. 6015(c)(3).  Thus, the Court begins its                
          analysis with section 6015(b).                                              
               A.  Section 6015(b)                                                    
               Section 6015(b) provides relief from joint and several                 
          liability for tax (including interest, penalties, and other                 
          amounts) to the extent that such liability is attributable to an            
          understatement of tax.  To be eligible for relief, the requesting           
          spouse must satisfy the following five elements of section                  
          6015(b)(1):                                                                 
                         (A) A joint return has been made for a                       
                    taxable year;                                                     
                         (B) on such return there is an understatement                
                    of tax attributable to erroneous items of 1                       
                    individual filing the joint return;                               
                         (C) the other individual filing the joint                    
                    return establishes that in signing the return he                  
                    or she did not know, and had no reason to know,                   
                    that there was such an understatement;                            
                         (D) taking into account all the facts and                    
                    circumstances, it is inequitable to hold the other                
                    individual liable for the deficiency in tax for                   
                    such taxable year attributable to such                            
                    understatement; and                                               
                         (E) the other individual [makes a valid                      
                    election] * * *                                                   
               Respondent does not appear to dispute that Ms. Wang                    
          satisfies two elements of section 6015(b); namely, those                    







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