- 7 - 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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011