Joyce A. Siddons, Petitioner, and Richard J. Siddons, Intervenor - Page 5

                                        - 4 -                                         
          not state his reasons for objecting to petitioner’s claim for               
          relief.  Moreover, intervenor was excused from testifying at the            
               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).                                                               

Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011