- 6 - married in June 1992, when she was pregnant with their second child, born the next year. They were divorced in May 2001. Petitioner and his former spouse filed a joint Federal income tax return for each year in issue. The illegal income is not included in the income reported on any of those returns. Petitioner was not aware of his former spouse’s involvement in the above-described scheme at the time he signed any of those income tax returns. Petitioner agrees that for each year in issue, respondent has properly determined the amount of the deficiency attributable to the omission of the illegal income. Nevertheless, according to petitioner, he should be relieved from liability for those deficiencies under section 6015. Discussion In general, spouses filing a joint Federal income tax return are jointly and severally responsible for the full income tax liability ultimately determined with respect to the year for which the return was filed. Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C. 276, 282 (2000). “Section 6015, however, provides various means by which a spouse can be relieved of this joint and several obligation.” Alt v. Commissioner, 119 T.C. 306, 311 (2002), affd. 101 Fed. Appx. 34 (6th Cir. 2004). One means is provided in section 6015(c). Upon election of its application by the taxpayer, that section limits anPage: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: March 27, 2008