- 4 -
not state his reasons for objecting to petitioner’s claim for
relief. Moreover, intervenor was excused from testifying at the
trial.4
Generally, spouses filing joint Federal income tax returns
are jointly and severally liable for the taxes due thereon. Sec.
6013(d)(3). Under certain circumstances, however, section 6015
provides relief from this general rule.5 Section 6015 applies to
any liability for tax arising after July 22, 1998, and to any
liability for tax 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.
Section 6015 provides three avenues for relief to a taxpayer
who has filed a joint return: (1) Section 6015(b) allows relief
for 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) more broadly
confers on the Secretary discretion to grant equitable relief for
4See supra note 3.
5Sec. 6015 was enacted as part of the Internal Revenue
Service Restructuring and Reform Act of 1998 (RRA 1998), Pub. L.
105-206, sec. 3201, 112 Stat. 734. Prior to 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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