- 8 - Rule 325, as amplified by King v. Commissioner, 115 T.C. 118 (2000), that respondent had notified Mr. Ogonoski that petitioner had filed a claim for relief from joint and several liability in this case. Mr. Ogonoski has not intervened in this case. Discussion Issue 1. Relief Under Section 6015 Generally, married taxpayers may elect to file a joint Federal income tax return. Sec. 6013(a). After making the election, each spouse generally is fully responsible for the accuracy of the return and jointly and severally liable for the entire tax due for that year. Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C. 276, 282 (2000). Petitioner requested relief under section 6015 from liability for the taxes reported on her 1989 through 1997 joint returns that were not paid when the returns were filed. Respondent determined petitioner was not entitled to the requested relief. In requesting relief, petitioner argues that when she signed the returns, it was reasonable for her to believe Mr. Ogonoski would pay the reported tax liabilities at some future time because there was a similar pattern of nonpayment for prior years, followed by his payment of the balances due for those years. Petitioner also argues she will suffer economic hardship if relief is not granted. If a taxpayer’s request for relief under section 6015 is denied, the taxpayer may petition this Court under sectionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011