Nancy M. O'Neill, Petitioner, and Robert B. Wollow, Intervenor - Page 5

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          denied petitioner’s request for innocent spouse relief.  On                 
          November 6, 2002, petitioner filed a petition with this Court               
          contesting respondent’s determination.                                      
               In general, spouses who file joint Federal income tax                  
          returns are jointly and severally liable for the full amount of             
          the tax liability.  Sec. 6013(d)(3); Butler v. Commissioner, 114            
          T.C. 276, 282 (2000).  Pursuant to section 6015, however, a                 
          spouse may seek relief from joint and several liability.3                   
               One form of relief from joint and several liability on a               
          joint return is equitable relief under section 6015(f).  Section            
          6015(f) provides:                                                           
                    SEC. 6015(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 individual           
                    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 liability.           
          The Commissioner uses guidelines prescribed in Rev. Proc. 2000-             
          15, 2000-1 C.B. 447, to determine whether a taxpayer qualifies              

               3Sec. 6015 applies to tax liabilities arising after July 22,           
          1998, and to tax liabilities arising on or before July 22, 1998,            
          but remaining unpaid as of such date.  Internal Revenue Service             
          Restructuring and Reform Act of 1998, Pub. L. 105-206, sec.                 
          3201(g), 112 Stat. 740.                                                     

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