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Relief under section 6015(c) generally is limited to the
portion of a tax deficiency that would be allocated to the
nonrequesting spouse if separate returns were filed. Sec.
6015(c)(1), (c)(3), (d).
Under section 6015(f), so called “equitable” relief from
joint liability may be available for tax deficiencies with
respect to which section 6015(b) and (c) relief has been denied
and for underpayments of Federal income taxes reported on Federal
income tax returns.
Equitable relief under section 6015(f) from joint liability
may be available where the facts and circumstances indicate that
it would be inequitable to hold the requesting spouse liable for
the tax underpayment or the tax deficiency. Sec. 6015(f)(1).
The relief available under section 6015(f) generally is
limited further to the portion of a tax underpayment or
deficiency attributable to an item of the nonrequesting spouse.
Rev. Proc. 2003-61, sec. 4.01(7), 2003-2 C.B. at 297.
Under Revenue Procedure 2003-61, section 4.01(7)(b), an
exception is provided to the above limitation denying section
6015(f) equitable relief from the portion of a tax liability
attributable to an item of the requesting spouse where the
requesting spouse establishes that her ownership of the assets
producing the income was only nominal.
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