Verna Doyel - Page 17

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          Regs., are applicable for elections or requests for relief filed            
          on or after July 18, 2002.  Sec. 1.6015-9, Income Tax Regs.                 
          Petitioner filed her election prior to this date; accordingly,              
          the regulations are inapplicable.                                           
               A.   Relief Under Section 6015(b)                                      
               To qualify for relief from joint and several liability under           
          section 6015(b)(1), a taxpayer must establish:                              
                    (A) a joint return has been made for a taxable                    
               year;                                                                  
                    (B) on such return there is an understatement of                  
               tax attributable to erroneous items of 1 individual                    
               filing the joint return;                                               
                    (C) the other individual filing the joint return                  
               establishes that in signing the return he or she did                   
               not know, and had no reason to know, that there was                    
               such understatement;                                                   
                    (D) taking into account all the facts and                         
               circumstances, it is inequitable to hold the other                     
               individual liable for the deficiency in tax for such                   
               taxable year attributable to such understatement; and                  
                    (E) the other individual elects (in such form as                  
               the Secretary may prescribe) the benefits of this                      
               subsection not later than the date which is 2 years                    
               after the date the Secretary has begun collection                      
               activities with respect to the individual making the                   
               election * * *.                                                        
               The requirements of section 6015(b)(1) are stated in the               
          conjunctive.  Accordingly, a failure to meet any one of them is             
          sufficient for us to find that petitioner does not qualify for              
          relief pursuant to section 6015(b).  Alt v. Commissioner, 119               








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