- 5 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: November 10, 2007