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provides relief for a portion of an understatement of tax for
taxpayers who are separated or divorced; and (3) section 6015(f)
more broadly confers on the Secretary discretion to grant
equitable relief for taxpayers who otherwise do not qualify for
relief under section 6015(b) or (c).
A requisite to granting relief under section 6015(b) or (c)
is the existence of a tax deficiency. Sec. 6015(b)(1)(B) and
(c)(1); Block v. Commissioner, 120 T.C. 62, 66 (2003).
Therefore, if there is no deficiency for the year for which
relief is sought, relief from joint and several liability is not
available under section 6015(b) or (c). See Washington v.
Commissioner, 120 T.C. 137, 147-148 (2003); see also Block v.
Commissioner, supra. In this case, for the 3 years in question,
there are underpayments of taxes arising from filed income tax
returns on which the taxes shown on those returns were not paid.
There are no deficiencies arising from the issuance by respondent
of notices of deficiencies. Therefore, because there are no tax
deficiencies, petitioner is not entitled to relief under section
6015(b) or (c). To that extent, therefore, respondent is
sustained. However, petitioner falls under the equitable relief
provision of 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
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