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section 6015(b). See Washington v. Commissioner, 120 T.C. 137,
146-147 (2003); see also Hopkins v. Commissioner, 121 T.C. 73, 88
(2003).
Section 6015(c) provides relief from joint liability for
spouses who filed a joint return if they are no longer married,
are legally separated, or have lived apart for a 12-month period.
Such spouses may elect to be treated, for purposes of determining
tax liability, as if separate returns had been filed. Section
6015(c)(1) provides proportionate relief for any “deficiency
which is assessed with respect to the return”. Relief is not
available under section 6015(c) with respect to an unpaid
liability for tax reported on the return. As noted, in the
present case, petitioner is seeking relief of the amounts
reflected as due on the 1992, 1993, 1994, 1995, 1996, 1997, and
1998 joint returns. Because there is no “deficiency” for 1992,
1993, 1994, 1995, 1996, 1997, and 1998, relief is not available
to petitioner under section 6015(c). See Washington v.
Commissioner, supra; see also Hopkins v. Commissioner, supra.
Therefore, the only opportunity for relief available to
petitioner is section 6015(f). Section 6015(f) provides as
follows:
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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