- 38 -
found to be owing. Sec. 6013(d)(3); Butler v. Commissioner,
supra at 282. In certain cases, however, an individual filing a
joint return may avoid joint liability for tax (including
interest, penalties, and other amounts) by qualifying for relief
under section 6015. The three types of relief prescribed in that
section are: (1) Full or apportioned relief under section
6015(b) (full/apportioned relief), (2) proportionate relief under
section 6015(c) (proportionate relief), and (3) equitable relief
under section 6015(f) (equitable relief). Except as otherwise
provided in section 6015, petitioner bears the burden of proving
her claim for relief under that section. See Alt v.
Commissioner, 119 T.C. 306, 311 (2002), affd. 101 Fed. Appx. 34
(6th Cir. 2004); see also Rule 142(a)(1).
Petitioner neither in her petition nor in her brief
specifies which of the three types of relief she is seeking under
section 6015. She alleges in her petition without further
explanation that she has commenced this proceeding under sections
6015 and 6213. She argues in her brief that she is entitled to
relief under section 6015 because (1) she did not in 1996
exercise dominion and control over the funds at issue and (2) she
was not aware when she signed her 1996 return that Bussell in
1996 had exercised dominion and control over those funds. We
address each of the three types of relief seriatim bearing in
mind this allegation and argument.
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