Elsie R. Garza - Page 7

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          He did not file a notice of intervention and did not appear or              
          participate in the trial of this case.                                      
               A taxpayer may petition this Court for review of the                   
          Commissioner’s determination denying relief under section 6015.             
          Sec. 6015(e)(1)(A).  The petition was filed timely in response to           
          the Final Notices that denied petitioner’s request for section              
          6015 relief from her income tax liabilities for the years at                
          issue.  Thus, the Court has jurisdiction to review the                      
          Commissioner’s denial of section 6015 relief for 2002 and 2003.             
               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 from           
          joint liability.  Section 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. 740.                               
               In general terms, there are three avenues of relief under              
          section 6015:  Section 6015(b) provides relief with respect to              
          certain erroneous items on the return, section 6015(c) provides             
          for a separation of liability for separated taxpayers, and                  
          section 6015(f) more broadly confers on the Secretary discretion            

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