- 5 - 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 understatement; (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 understatement. 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 reliefPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: March 27, 2008