Teresa G. Butner - Page 17




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               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 liabilities             







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