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Commissioner, 115 T.C. 183, 188 (2000), affd. 282 F.3d 326 (5th
Cir. 2002). However, relief from joint and several liability is
available to certain taxpayers under section 6015. There are
three types of relief available under section 6015: (1) Section
6015(b)(1) provides full or apportioned relief from joint and
several liability; (2) section 6015(c) provides proportionate tax
relief to divorced or separated taxpayers; and (3) section
6015(f) provides equitable relief from joint and several
liability in certain circumstances if neither section 6015(b) nor
(c) is available.
Petitioner concedes that she is not eligible for relief
under either section 6015(b) or (c). Petitioner has instead
requested equitable relief under section 6015(f).
Section 6015(f) provides:
SEC. 6015(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.
We review respondent’s denial of equitable relief to
petitioner after a trial de novo and under an abuse of discretion
standard. Ewing v. Commissioner, 122 T.C. (2004); Cheshire
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