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6015. Sec. 6015(a). A requesting spouse may request relief from
liability under section 6015(b) or, if eligible, may allocate
liability according to provisions under section 6015(c). Sec.
6015(a). If relief is not available under section 6015(b) or
(c), an individual may seek equitable relief from joint and
several liability if “taking into account all the facts and
circumstances, it is inequitable to hold the individual liable
for any unpaid tax”. Sec. 6015(f).
Petitioner has failed to address the applicable statutory
provisions, the adjustments involved in respondent’s
determination, or the relevant facts. Petitioner argues that she
did “not know the facts as to amounts owed, when, or why, as
petitioner never had anything to do with these matters”.
Petitioner generally claims that the division of property
pursuant to the divorce decree was not equitable; she received
properties that were foreclosed; the divorce decree was signed
without notice to her; and “the system” failed to treat her
fairly.
1989 and 1990
Under section 6015(b) and (c), relief from joint and several
liability is available only from proposed or assessed
deficiencies. Sec. 6015(b)(1)(D), (c)(1). Neither section
6015(b) nor section 6015(c) permits relief from liabilities that
were reported on a return but remained unpaid. Hopkins v.
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Last modified: May 25, 2011