Yvonne C. Lopez - Page 6

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          petition contesting respondent’s determination was filed with               
          this Court.  The petition did not conform with Rule 321(b).                 
          Consequently, on February 11, 2003, we ordered petitioner to file           
          a proper “Amended Petition for Determination of Relief From Joint           
          and Several Liability on a Joint Return” (amended petition) by              
          March 11, 2003.  Petitioner submitted an amended petition that we           
          filed on March 12, 2003.                                                    
                                       OPINION                                        
               In general, spouses who file joint Federal income tax                  
          returns are jointly and severally liable for the full amount of             
          the tax liability.  Sec. 6013(d)(3); Butler v. Commissioner, 114            
          T.C. 276, 282 (2000).  Pursuant to section 6015, however, a                 
          spouse may seek relief from joint and several liability.5                   
               One form of relief from joint and several liability is                 
          equitable relief under section 6015(f).  Section 6015(f)                    
          provides:                                                                   
                    SEC. 6015(f).  Equitable Relief.–-Under procedures                
               prescribed by the Secretary, if--                                      
                         (1) taking into account all the facts and                    

               4(...continued)                                                        
          that the reference to 1991 and 1996 in the notice of                        
          determination was erroneous and that the only years in issue are            
          1992 through 1995.                                                          
               5Sec. 6015 applies to tax liabilities arising after July 22,           
          1998, and to tax liabilities arising on or before July 22, 1998,            
          but remaining unpaid as of such date.  Internal Revenue Service             
          Restructuring and Reform Act of 1998, Pub. L. 105-206, sec.                 
          3201(g), 112 Stat. 740.                                                     





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