- 19 - 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.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011