- 5 - did not determine at that time what portion of the underpayment was attributable to petitioner, but she did conclude that petitioner was not entitled to relief under section 6015(f). On or about July 19, 2004, petitioner appealed Ms. Wilce’s denial of relief. On or about March 30, 2005, Appeals Officer Leslie Hackmeister (Ms. Hackmeister) reviewed petitioner’s appeal. In the case memorandum she prepared reflecting her review, Ms. Hackmeister stated, among other things, that the underpayment is attributable to Mr. Parker’s self-employment income. On March 30, 2005, respondent issued a Notice of Determination denying petitioner’s request for relief under section 6015(f). On June 24, 2005, a petition contesting respondent’s determination was filed with this Court. Discussion In general, spouses who file a joint Federal income tax return are jointly and severally liable for the full amount of the tax liability shown or required to be shown on the return. Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C. 276, 282 (2000). However, a spouse may seek relief from joint and several liability under section 6015 if certain requirements are met. In this case petitioner seeks equitable relief under section 6015(f). Section 6015(f) provides: SEC. 6015(f). Equitable Relief.--Under procedures prescribed by the Secretary, if--Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007