Lois E. Ordlock - Page 19

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          of section 6015 and refrain from looking to State law, a question           
          arises as to where courts should derive such guidance.                      
               In addition, petitioner’s approach would lead to a very                
          complex factual analysis to trace the acquisition of the assets             
          used to make over 20 years of tax payments.  It is likely that a            
          married couple will continue to acquire assets throughout their             
          relationship.  Tracing the acquisition of those assets to                   
          ascertain what assets should be attributed to which spouse is an            
          administrative nightmare that would severely impede collection              
          and lead to layers of judicial interpretation and analysis.  We             
          think Congress did not intend to create such a difficult factual            
          issue in adopting section 6015.                                             
          III.  Concern With Denial of Effective Relief                               
               Petitioner suggests that our holding today will frustrate              
          congressional intent by effectively denying section 6015 relief             
          to persons in community property States.  This suggestion appears           
          to assume that the marital community continues after the year for           
          which relief is sought, which is obviously not always the case.             
          Nevertheless, we will examine the consequences of our holding               
          where the spouse seeking relief remains married in a community              
          property State after the taxable year in question, as in the                
          present case.                                                               
               The Ordlocks remained married in California.  They continued           
          to accumulate assets and make payments on their joint tax                   
          liabilities for 1982, 1983, and 1984 for over two decades.  If              




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