Amy A. Christman - Page 6




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          Determination Concerning Your Request for Relief under the                  
          Equitable Relief Provision of Section 6015(f) denying petitioner            
          her request for relief from joint and several liability under               
          section 6015(f) for the years 1998 and 1999.                                
               On June 27, 2005, the petition was filed with this Court               
          with respect to petitioner’s 1998 and 1999 taxable years.                   
          Petitioner claims she is entitled to relief from joint and                  
          several liability for those years under section 6015(f).                    
          Pursuant to Rule 325 and King v. Commissioner, 115 T.C. 118                 
          (2000), respondent served Mr. Christman with notice of this                 
          proceeding and his right to intervene.  Mr. Christman did not               
          file a notice of intervention and did not appear or participate             
          in the trial of this case.                                                  
                                     Discussion                                       
               Generally, married taxpayers may elect to file a Federal               
          income tax return jointly.  Sec. 6013(a).  Each spouse filing a             
          joint return is jointly and severally liable for the accuracy of            
          the return and the entire tax due.  Sec. 6013(d)(3).  Under                 
          certain circumstances, however, section 6015 provides relief to a           
          spouse from this general rule.4                                             

               4  Sec. 6015 applies to any liability for tax arising after            
          July 22, 1998, and to any liability for tax arising on or before            
          July 22, 1998, remaining unpaid as of such date.  Internal                  
          Revenue Service Restructuring and Reform Act of 1998, Pub. L.               
          105-206, sec. 3201(g), 112 Stat. 734, 740.  The Tax Relief and              
          Health Care Act of 2006, Pub. L. 109-432, div. C, sec. 408, 120             
                                                             (continued...)           






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