Dawn E. Giles - Page 7

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          section 6015(b).                                                            
               We next address whether petitioner is eligible for relief              
          under section 6015(c).  Section 6015(c) provides for allocation             
          of tax liability between the joint filers.                                  
               Petitioner received two Forms W-2 for taxable year 1995, one           
          of which was omitted from the 1995 tax return.  Thus, the                   
          deficiency for taxable year 1995 arose from the omission of                 
          petitioner’s income.                                                        
               On these facts, we conclude that any allocation of tax                 
          liability would be to petitioner.  Accordingly, we sustain                  
          respondent’s determination that petitioner is ineligible for                
          relief under section 6015(c).                                               
               Finally, we address whether petitioner is eligible for                 
          relief under section 6015(f).  Section 6015(f) provides for                 
          equitable relief, at the Secretary’s discretion, if relief under            
          section 6015(b) and (c) is not available.  Thus, we review                  
          respondent’s denial of equitable relief under an abuse of                   
          discretion standard.  Butler v. Commissioner, 114 T.C. 276, 292             
          (2000).  Petitioner bears the burden of proving that respondent             
          abused his discretion in denying equitable relief under section             
          6015(f).  Jonson v. Commissioner, 118 T.C. 106, 125 (2002), affd.           
          353 F.3d 1181 (10th Cir. 2003).                                             
               Rev. Proc. 2000-15, 2000-1 C.B. 447, describes the                     
          procedures for determining eligibility for equitable relief under           






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