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section 6015(b), respondent stated that “You failed to meet all
the requirements of IRC section 6015(b); therefore, you do not
qualify for relief under the law.” With respect to his
determination under section 6015(f), respondent stated that “You
are not eligible for relief under the law since the majority of
the factors weigh against equitable relief.”
On March 3, 2003, petitioner filed a timely petition with
this Court pursuant to section 6015(e) seeking review of
respondent’s determination with respect to petitioner’s 1980
through 1986 taxable years.
OPINION
In general, taxpayers filing joint Federal income tax
returns are each responsible for the accuracy of their return and
are jointly and severally liable for the entire tax liability due
for that year. Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C.
276, 282 (2000). In certain circumstances, however, a spouse may
obtain relief from joint and several liability by satisfying the
requirements of section 6015.9
Section 6015(a)(1) provides that a spouse who has made a
joint return may elect to seek relief from joint and several
liability under section 6015(b) (dealing with relief from
9Sec. 6015 applies to tax liabilities arising after July 22,
1998, and to tax liabilities arising on or before July 22, 1998,
that remain unpaid as of such date. Internal Revenue Service
Restructuring and Reform Act of 1998, Pub. L. 105-206, sec.
3201(g), 112 Stat. 740.
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