- 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.
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