- 43 - At the time of the trial, the residence in which petitioner and Mr. Korchak were living that petitioner owned was subject to liabilities totaling $139,000.19 Petitioner filed a second petition with the Court with respect to her taxable year 1982. In that petition, petitioner claimed that she is entitled to relief under section 6015 with respect to the deficiency in tax assessed against petitioner and Mr. Korchak for their taxable year 1982 as well as interest thereon as provided by law. OPINION Section 6015(b) Introduction Petitioner claims that she is entitled to relief under section 6015(b) for her taxable year 1982.20 Section 6015(b) provides in pertinent part: SEC. 6015. RELIEF FROM JOINT AND SEVERAL LIABILITY ON JOINT RETURN. * * * * * * * (b) Procedures For Relief From Liability Applicable to All Joint Filers.-- (1) In general.--Under procedures prescribed by the Secretary, if– 19The record does not disclose whether petitioner or Mr. Korchak had any other liabilities at the time of the trial. 20In the alternative, petitioner claims relief under sec. 6015(f) for her taxable year 1982.Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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