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spouse) may, however, seek relief from joint and several
liability by following procedures established in section 6015.
Sec. 6015(a).
Under section 6015(a), a requesting spouse may seek relief
from liability under section 6015(b) or, if eligible, may
allocate liability according to the provisions under section
6015(c). If relief is not available under either section 6015(b)
or (c), then an individual may seek equitable relief under
section 6015(f). Section 6015(f) permits relief from joint and
several liability where “it is inequitable to hold the individual
liable for any unpaid tax or any deficiency (or any portion of
either)”.
Petitioner contends that she is entitled to equitable relief
under section 6015(f) for taxable years 1989 through 1992 and
that respondent erred in denying her request for such relief.3
We have jurisdiction to review a denial of a request for
equitable relief under section 6015(f). Fernandez v.
Commissioner, 114 T.C. 324, 332 (2000). Our review is not
limited to respondent’s administrative record. Ewing v.
Commissioner, 122 T.C. 32 (2004).
3 As indicated earlier, respondent conceded that the issue
of relief with respect to 1992 is moot.
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