Francenia M. Griffin - Page 8

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               Section 6015 significantly relaxed the requirements for                
          relief from joint liability by providing 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 and the avenue directly at issue in this case)            
          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 under section 6015 from                    
          liability for the payment of the taxes reported on the 1992,                
          1993, 1994, 1995, 1996, 1997, and 1998 joint returns that were              
          not paid when the returns were filed.  Respondent treated                   
          petitioner’s request for relief under section 6015 as an election           
          under section 6015(b), (c), and (f), and determined that                    
          petitioner was not entitled to the requested relief.                        
               If a taxpayer’s request for relief under section 6015 is               
          denied, the taxpayer may petition this Court, pursuant to section           
          6015(e)(1), for a review of such determination.  Section                    

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