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argues that she was unaware that there was an understatement of
tax on the first amended joint return that resulted in that
return’s only partially correcting the understatement on the
original joint return. Accordingly, petitioner contends that she
should be granted relief from joint and several liability for the
interest that accrued as a result of that understatement on the
first amended joint return. In addition to her argument that she
is eligible for relief under either section 6015(b) or (c),
petitioner argues that respondent abused his discretion by
denying her equitable relief from joint and several liability for
the 1992-1994 interest liability under section 6015(f).
Petitioner does not contend that she should be granted relief
from joint and several liability for the remaining amount of the
1990-1992 interest liability under the provisions of section
6015.
Respondent argues that petitioner is not eligible for relief
under either section 6015(b) or (c). Moreover, respondent
contends that there was no abuse of discretion in denying
petitioner’s request for equitable relief from joint and several
liability for any portion of the unpaid interest under section
6015(f). Respondent has not pursued the argument that petitioner
was ineligible for relief under section 6015 because Apostle did
not sign the second amended joint return.
Relief Under Section 6015(b) and (c)
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Last modified: May 25, 2011