- 10 - 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)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011