Mary Elizabeth Cumings - Page 6




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          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--                                       






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