Carolyn A. Glenn - Page 10

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          119 T.C. 306, 311 (2002), affd. 101 Fed. Appx. 34 (6th Cir.                 
          2004).                                                                      
               As a general rule, married taxpayers may elect to file a               
          joint Federal income tax return.  Sec. 6013(a).  After making the           
          election, each spouse generally is jointly and severally liable             
          for the entire tax due for that taxable year.  Sec. 6013(d)(3).             
          In certain situations, however, a joint return filer can avoid              
          such joint and several liability by qualifying for relief                   
          therefrom under section 6015.7                                              
               Section 6015 provides three avenues for obtaining relief to            
          a taxpayer who has filed a joint return:  (1) Section 6015(b)               
          provides full or apportioned relief with respect to                         
          understatements of tax attributable to certain erroneous items on           
          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 requested relief pursuant to section 6015(f) from           
          liability for the unpaid amount of additional tax liability                 


          7Sec. 6015 was enacted as part of the Internal Revenue                      
          Service Restructuring and Reform Act of 1998, Pub. L. 105-206,              
          sec. 3201, 112 Stat. 734.  Before the enactment of sec. 6015,               
          relief from the imposition of joint and several liability for               
          spouses filing joint returns was available under sec. 6013(e).              




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