Tracie Young - Page 8

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          (c), an individual may seek equitable relief under section                  
          6015(f), which may be granted by the Commissioner in his                    
               In this case, petitioner contends that she is entitled to              
          full relief from liability under section 6015.2  Our jurisdiction           
          to review petitioner’s request for relief is conferred by section           
          6015(e), which allows a spouse who has requested relief from                
          joint and several liability to contest the Commissioner’s denial            
          of relief by filing a timely petition in this Court.  We address            
          petitioner’s request for relief under subsections (b), (c), and             
          (f) of section 6015 in turn.                                                
               A.  Section 6015(b)                                                    
               Section 6015(b)(1) authorizes the Commissioner to grant                
          relief from joint and several liability if the taxpayer satisfies           
          each requirement of subparagraphs (A) through (E).  Section                 
          6015(b)(1) provides:                                                        

          2Presumably, petitioner’s claim for relief includes a refund                
          of her 2001 overpayment of $2,434 which the Commissioner applied            
          toward petitioner and Mr. Glaze’s 1995 income tax liability.                
          Sec. 6015(g) governs the allowance of credits and refunds in                
          cases where the taxpayer is granted relief under sec. 6015.                 
          Except as provided otherwise in sec. 6015(g) and in secs. 6511,             
          6512(b), 7121, and 7122, a credit or refund is allowed or made to           
          the extent attributable to the application of sec. 6015.  Sec.              
          6015(g)(1).  A tax credit or refund is allowed only if petitioner           
          qualifies for innocent spouse relief under sec. 6015(b) or if the           
          Internal Revenue Service exercises its authority to provide                 
          equitable relief pursuant to sec. 6015(f).  No credit or refund             
          is allowed where a taxpayer obtains relief after making a                   
          separate liability election.  See sec. 6015(g)(3).                          

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