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SEC. 6015. RELIEF FROM JOINT AND SEVERAL LIABILITY ON
JOINT RETURN.
* * * * * * *
(f) Equitable Relief.–Under procedures prescribed
by the Secretary, if--
(1) taking into account all the facts and
circumstances, it is inequitable to hold the indi-
vidual liable for any unpaid tax or any deficiency
(or any portion of either); and
(2) relief is not available to such individual
under subsection (b) or (c),
the Secretary may relieve such individual of such lia-
bility.
We have found that petitioner is not entitled to relief under
section 6015(b) for any of the taxable years 1989, 1991, 1992, and
1993. The parties agree that petitioner is not entitled to relief
under section 6015(b) for the unpaid liability relating to the
taxable year 1990. The parties also agree that petitioner is not
entitled to relief under section 6015(c) for any of the taxable
years at issue. We conclude that section 6015(f)(2) is satisfied
with respect to each of those years.
As directed by section 6015(f), respondent has prescribed
procedures in Revenue Procedure 2000-15, 2000-1 C.B. 447 (Revenue
Procedure 2000-15),38 that are to be used in determining whether it
38We note that Rev. Proc. 2003-61, 2003-32 I.R.B. 296 (Reve-
nue Procedure 2003-61), superseded Revenue Procedure 2000-15.
Revenue Procedure 2003-61 is effective for requests for relief
under sec. 6015(f) which were filed on or after Nov. 1, 2003, and
for requests for such relief which were pending on, and for which
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