Patricia A. Hendricks and John J. Hendricks - Page 11

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          to provisions under section 6015(c).  Sec. 6015(a).  If relief is           
          not available under section 6015(b) or (c), an individual may               
          seek equitable relief under section 6015(f).                                
               To qualify for relief from joint and several liability under           
          section 6015(b)(1), a requesting spouse must establish:                     
                    (A) a joint return has been made for a taxable                    
                    (B) on such return there is an understatement of                  
               tax attributable to erroneous items of 1 individual                    
               filing the joint return;                                               
                    (C) the other individual filing the joint return                  
               establishes that in signing the return he or she did                   
               not know, and had no reason to know, that there was                    
               such understatement;                                                   
                    (D) taking into account all the facts and                         
               circumstances, it is inequitable to hold the other                     
               individual liable for the deficiency in tax for such                   
               taxable year attributable to such understatement; and                  
                    (E) the other individual elects (in such form as                  
               the Secretary may prescribe) the benefits of this                      
               subsection not later than the date which is 2 years                    
               after the date the Secretary has begun collection                      
               activities with respect to the individual making the                   
               election, * * *.                                                       
               The requirements of section 6015(b)(1) are stated in the               
          conjunctive.  Accordingly, a failure to meet any one of them                
          prevents a requesting spouse from qualifying for the relief                 
          offered therein.  Alt v. Commissioner, 119 T.C. 306, 313 (2002),            
          affd. 101 Fed. Appx. 34 (6th Cir. 2004).                                    
               Respondent does not dispute that petitioner satisfies the              
          requirements of subparagraphs (A), (B), and (E) of section                  

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