Ingrid Capehart - Page 19

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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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