- 10 - with respect to liability for taxes arising or remaining unpaid on or after the December 20, 2006, date of enactment. Id. Once again, in light of the change in the law, the Court on December 26, 2006, issued an order directing the parties to show cause why the earlier dismissal for lack of jurisdiction should not be vacated. Respondent filed a response confirming that petitioner’s liabilities for the relevant years remain unpaid and that the Court now has jurisdiction to review the underlying determination. The Court issued an order vacating the October 24, 2006, dismissal on January 11, 2007. This matter is now in a posture to be addressed on the merits. OPINION As a general rule, section 6013(d)(3) provides that “if a joint return is made, the tax shall be computed on the aggregate income and the liability with respect to the tax shall be joint and several.” An exception to such joint and several liability exists, however, for spouses able to satisfy the statutory requirements for relief set forth in section 6015. Section 6015 authorizes three types of relief. Subsection (b) provides a form of full or partial relief available to all joint filers and similar to, but less restrictive than, that previously afforded by former section 6013(e), which was repealed for taxes remaining unpaid as of July 22, 1998, or arising after that date. Subsection (c) permits a taxpayer who has divorced orPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 NextLast modified: November 10, 2007