- 17 - On December 15, 2003, petitioner filed a petition with the Court for review of respondent's determination denying her request for relief under section 6015 with respect to each of the taxable years 1994, 1995, 1998, and 1999. OPINION In general, each of the spouses who file jointly an income tax return is responsible for the accuracy of, and is jointly and severally liable for the entire liability shown due in, such return. Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C. 276, 282 (2000). In certain circumstances, a spouse may obtain relief from such joint and several liability if the requirements of section 6015 are satisfied. Section 6015 applies to any liability for tax arising after July 22, 1998, and to tax liabilities arising on or before July 22, 1998, that remain unpaid as of such date. Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3201(g), 112 Stat. 740. In the present case, the respective liabilities of petitioner and Mr. Butner arose with respect to the taxable years 1994, 1995, 1998, and 1999. The respective liabilities of petitioner and Mr. Butner for the taxable years 1994 and 1995 arose before July 22, 1998, but remained unpaid as of that date. The respective liabilities of petitioner and Mr. Butner for the taxable years 1998 and 1999 arose after July 22, 1998. Section 6015 is applicable to the respective liabilitiesPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: November 10, 2007