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liability for an understatement of tax on a joint return).
Section 6015(a)(2) provides that a spouse who is eligible to do
so may elect to limit that spouse’s liability for any deficiency
with respect to a joint return under section 6015(c). Relief
from joint and several liability under section 6015(b) or (c) is
available only with respect to a deficiency for the year for
which relief is sought. Sec. 6015(b)(1)(D) and (c)(1); see H.
Conf. Rept. 105-599, at 252-254 (1998), 1998-3 C.B. 747, 1006-
1008. If relief is not available under either section 6015(b) or
(c), an individual may seek equitable relief under section
6015(f), which may be granted by the Commissioner in his
discretion.
In this case, petitioner contends that she is entitled to
full relief from liability under section 6015(b) or (f).
Alternatively, petitioner seeks full relief under section
6015(c), contending that no part of the deficiency is allocable
to her.
Our jurisdiction to review petitioner’s request for relief
is conferred by section 6015(e), which allows a spouse who has
requested relief from joint and several liability to contest the
Commissioner’s denial of relief by filing a timely petition in
this Court. We address petitioner’s request for relief under
subsections (b), (c), and (f) of section 6015 in turn.
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