- 37 - For the sake of completeness, we shall address whether, assuming arguendo that we had not held that section 6015(g)(2) precludes petitioner from the relief that she claims under section 6015(b) and (f), petitioner would be entitled to such relief. Section 6015(b) Introduction Petitioner claims that she is entitled to relief under section 6015(b) for each of the taxable years 1989, 1991, 1992, and 1993.33 Section 6015(b) provides: SEC. 6015. RELIEF FROM JOINT AND SEVERAL LIABILITY ON JOINT RETURN. * * * * * * * (b) Procedures For Relief From Liability Applicable to All Joint Filers.-- (1) In general.–-Under procedures prescribed by the Secretary, if-- (A) a joint return has been made for a taxable year; (B) on such return there is an under- statement 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 33In the alternative, petitioner claims relief under sec. 6015(f) for each of the taxable years 1989, 1991, 1992, and 1993. She also claims relief under that section for the taxable year 1990.Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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