John William Hollis - Page 8

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          Secs. 6015(b)(3), 6662(d)(2)(A); Washington v. Commissioner,                
          supra at 146 n.5.  In this case, there is no understatement of              
          tax because the amount of tax required to be shown on the return            
          is the amount shown on the return.  Thus, petitioner is not                 
          entitled to relief under section 6015(b).                                   
          C.   Whether Petitioner Is Entitled to Relief From Joint                    
               Liability Under Section 6015(c)                                        
               Petitioner contends that he is entitled to relief from joint           
          liability under section 6015(c).  We disagree.  Section 6015(c)             
          provides relief from a tax liability resulting from a deficiency            
          on a joint return for taxpayers who are divorced, legally                   
          separated, or otherwise living apart.  There is no deficiency in            
          this case because the amount of tax required to be shown on the             
          return is the amount of tax shown on the return.  See sec.                  
          6211(a).  Thus, petitioner is not entitled to relief from joint             
          liability under section 6015(c).  See Washington v. Commissioner,           
          supra at 147.                                                               
          D.   Whether Petitioner Is Entitled to Relief From Joint                    
               Liability Under Section 6015(f)                                        
               1.   Relief Under Section 6015(f)                                      
               Section 6015(e) gives this Court jurisdiction to determine             
          whether a taxpayer is entitled to relief from joint liability               
          under section 6015.  As a result, a taxpayer is entitled to                 
          relief from joint liability under section 6015(f) if the Court              
          determines that, taking into account all the facts and                      






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