- 4 - were paid from the joint bank account. Petitioner and Mr. Gonce both wrote checks from the joint bank account during the years in issue, and petitioner reviewed their monthly bank statements and balanced their checkbooks at least sometimes. Petitioner made deposits, wrote checks, and withdrew funds from the joint bank account during the years in issue. During their marriage, petitioner knew that Mr. Gonce always bought on credit and that he and petitioner regularly spent more money than they earned. Pursuant to petitioner’s and Mr. Gonce’s divorce decree, petitioner received sole title to the Gonces’ house by quitclaim deed. The divorce decree also divided the Gonces’ joint tax liabilities, requiring each spouse to pay one-half of their total tax liabilities at the time of the divorce. OPINION Generally, married taxpayers may elect to file a joint Federal income tax return. Sec. 6013(a). When a husband and wife elect to file a joint Federal income tax return, they are jointly and severally liable for the entire tax due on that return. Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C. 276, 282 (2000). However, section 6015 provides for relief for a requesting spouse from joint and several liability in certain circumstances. Section 6015(b) provides general relief from joint and several liability if certain requirements are met, and section 6015(c), if applicable, provides for an allocation ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: March 27, 2008