Joseph Dutton - Page 7

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          II. Whether the Offer in Compromise Bars Petitioner From Seeking            
               Relief From Joint and Several Liability Under Section 6015             
               Section 6015 was enacted on July 22, 1998, as part of the              
          Internal Revenue Service Restructuring and Reform Act of 1998,              
          Pub. L. 105-206, sec. 3201(a), 112 Stat. 734.  It was given                 
          retroactive effect with respect to any liability for tax                    
          remaining unpaid as of July 22, 1998.  Id. sec. 3201(g)(1), 112             
          Stat. 740.                                                                  
               Section 6015 provides three avenues of relief from joint and           
          several liability.  Section 6015(b) provides relief similar to              
          that available under former section 6013(e), and also allows a              
          spouse to be relieved from a portion of an understatement of tax.           
          Section 6015(c) generally provides for an allocation of liability           
          for deficiencies as if the spouses had filed separate returns.              
          Section 6015(f) allows for equitable relief in situations where             
          relief is unavailable under section 6015(b) or (c).                         
               Section 6015(g) governs the allowance of credits and refunds           
          in cases where the taxpayer is granted relief under section 6015.           
          Except as provided otherwise in section 6015(g) and in sections             
          6511, 6512(b), 7121, and 7122, credit or refund is allowed or               
          made to the extent attributable to the application of section               
          6015.  Sec. 6015(g)(1).  No refund or credit is allowed under               
          section 6015(c).  Sec. 6015(g)(3).                                          
               Petitioner’s claim for relief is under section 6015(b), (c),           
          and (f) and includes tax liabilities that were covered by the               





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