Stacy Lee Gonce - Page 5

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          liability as if the spouses had filed separate returns.  If                 
          neither section 6015(b) nor (c) applies, section 6015(f) provides           
          for relief on other equitable grounds.                                      
               Section 6015(b) provides, in pertinent part, as follows:               
                    SEC. 6015(b).  Procedures for Relief From                         
               Liability Applicable to All Joint Filers.--                            
                         (1) In general.--Under procedures prescribed                 
                    by the Secretary, if--                                            
                              (A) a joint return has been made for a                  
                         taxable year;                                                
                              (B) on such return there is an                          
                         understatement of tax attributable to                        
                         erroneous items of 1 individual filing the                   
                         joint return;                                                
                              (C) the other individual filing the                     
                         joint return establishes that in signing the                 
                         return he or she did not know, and had no                    
                         reason to know, that there was such                          
                              (D) taking into account all the facts                   
                         and circumstances, it is inequitable to hold                 
                         the other individual liable for the                          
                         deficiency in tax for such taxable year                      
                         attributable to such understatement; and                     
                     *      *      *      *      *      *      *                      
                    then the other individual shall be relieved of                    
                    liability for tax (including interest, penalties,                 
                    and other amounts) for such taxable year to the                   
                    extent such liability is attributable to such                     
               The requirements of section 6015(b)(1) are stated in the               
          conjunctive.  Accordingly, a failure to meet any one of them                
          prevents a requesting spouse from qualifying for the relief                 

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Last modified: March 27, 2008