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the return; (2) section 6015(c) provides relief for a portion of
an understatement of tax for taxpayers who are separated or
divorced; and (3) section 6015(f) (potentially the broadest of
the three avenues) confers upon the Secretary discretion to grant
equitable relief for taxpayers who otherwise do not qualify for
relief under section 6015(b) or (c).
Petitioner requests relief pursuant to section 6015 from
liability for one-half of the 10-percent additional tax
attributable to the early withdrawal. In addition, petitioner
argues that his and Ms. Glenn’s judgment for dissolution of
marriage required each party to pay half of the liabilities that
were incurred during the marriage.7 We will consider
petitioner’s request for relief under section 6015 as an election
under section 6015(b), (c), and (f).
B. Section 6015(b) Analysis
Section 6015(b) provides, in pertinent part as follows:
SEC. 6015(b). Procedures For Relief From Liability
Applicable to All Joint Filers.--
(1) In general.--Under procedures prescribed by
the Secretary, if–
(A) a joint return has been made for a
taxable year;
7We need not discuss petitioner’s claim regarding the
judgment for dissolution of marriage because such a claim is a
State matter.
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