- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011