Timothy J. Glenn - Page 11

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          return preparer with all their relevant tax information, they               
          relied reasonably and in good faith on the tax preparer to                  
          prepare an accurate tax return.  We conclude that petitioner                
          acted with reasonable cause and good faith as to the underpayment           
          resulting from the additional tax in issue.  Accordingly, we hold           
          that petitioner is not liable for the accuracy-related penalty              
          pursuant to section 6662(a).                                                
          2.  Relief From Joint and Several Liability Pursuant to Section             
          6015                                                                        
               Under present law, there are three primary jurisdictional              
          bases upon which this Court may review a claim for relief from              
          joint and several liability.  First, a claim may be raised as an            
          affirmative defense in a petition for redetermination of a                  
          deficiency filed pursuant to section 6213(a).  Butler v.                    
          Commissioner, 114 T.C. 276, 287-288 (2000).  A second basis upon            
          which we may exercise jurisdiction is contained in section                  
          6015(e).  This provision allows a spouse who has requested relief           
          to petition the Commissioner’s denial of relief or to petition              
          the Commissioner’s failure to make a timely determination.  Such            
          cases are referred to as “stand alone” cases, in that they are              
          independent of any deficiency proceeding.  Fernandez v.                     
          Commissioner, 114 T.C. 324, 329 (2000).  A third situation where            
          we may exercise jurisdiction to determine relief from joint and             
          several liability is where the issue is properly raised in a                







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