William G. Applegate - Page 12

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          individual who files a joint return.2  Relief from the 1999                 
          underpayment is not available to Ms. Wang under section 6015(b)             
          or (c).  Thus Ms. Wang has satisfied section 6015(f)(2).                    
               As contemplated by section 6015(f), the Commissioner has               
          prescribed guidelines in Rev. Proc. 2000-15, sec. 4.02, 2000-1              
          C.B. 447, 448, to be used in determining whether an individual              
          qualifies for relief under that section.3  Rev. Proc. 2000-15,              
          sec. 4.01, 2001-1 C.B. at 448, sets forth the threshold                     
          conditions that must be satisfied before the Commissioner will              
          consider a request for equitable relief under section 6015(f).              



               2Sec. 6015 provides, in pertinent part, as follows:                    
               SEC. 6015.  RELIEF FROM JOINT AND SEVERAL LIABILITY ON                 
                         JOINT RETURN.                                                
                    (f) Equitable Relief.--Under procedures prescribed by             
               the Secretary, if–-                                                    
                         (1) taking into account all the facts and                    
                    circumstances, it is inequitable to hold the individual           
                    liable for any unpaid tax or any deficiency (or any               
                    portion of either); and                                           
                         (2) relief is not available to such individual               
                    under subsection (b) or (c),                                      
               the Secretary may relieve such individual of such liability.           
               3The guidelines applicable herein are set forth in Rev.                
          Proc. 2000-15, 2000-1 C.B. 447, which was in effect at the time             
          Ms. Wang's request for relief was made.  Rev. Proc. 2000-15,                
          supra, has been superseded by Rev. Proc. 2003-61, 2003-32 I.R.B.            
          296, effective for requests for relief filed on or after Nov. 1,            
          2003.                                                                       





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