- 3 - claim by petitioner under section 6015, respondent’s determinations contained in the notice of deficiency are not in dispute. Petitioner knew of Ms. Becherer’s employment with the three employers. Petitioner occasionally assisted Ms. Becherer in performing her employment duties for Trader Publications and Pennysaver. When the 1996 Federal income tax return was prepared, petitioner was a sophomore or junior in college, and Ms. Becherer held a high school general equivalency diploma. Petitioner had an opportunity to review the 1996 Federal income tax return before the return was filed. Petitioner currently holds a degree in communications from the University of Miami and is employed as a video editor for E-Entertainment Network. Discussion In general, spouses filing joint Federal income tax returns are jointly and severally liable for all taxes due. Sec. 6013(d)(3). Under certain circumstances, however, section 6015 provides relief from this general rule. Except as otherwise provided in section 6015, petitioner bears the burden of proof.3 3 Petitioner does not contend that sec. 7491(a) is applicable to this case, nor is there evidence that the examination commenced after July 22, 1998. Also, we note that some documents in the record indicate that the examination began prior to July 22, 1998.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011