Maureen Monsour - Page 37

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               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.                                                                       





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