- 7 - but she failed to do so. Thus, petitioner is not eligible for relief from joint and several liability for the years in issue under section 6015(b). Section 6015(c) provides procedures for a requesting spouse, where a deficiency has been assessed and the taxpayers who filed jointly are now divorced, legally separated, or no longer members of the same household, to elect to limit her liability to the amount of a deficiency properly allocable to the requesting spouse. Sec. 6015(c)(3). However, the requesting spouse is ineligible to elect section 6015(c) relief if she had actual knowledge, when signing the return, of any item giving rise to a deficiency that is allocable to the other spouse. Sec. 6015(c)(3)(C). There is no dispute that petitioner had actual knowledge of the payments she and Mr. Gonce received for maintaining their respective newspaper routes; those payments gave rise to the deficiencies in tax for the years in issue. Thus, she does not qualify for relief under section 6015(c). See Mitchell v. Commissioner, T.C. Memo. 2000-332, affd. 292 F.3d 800 (D.C. Cir. 2002). Section 6015(f) provides for equitable relief if, taking into account all of the facts and circumstances, it is inequitable to hold the requesting spouse liable for the deficiency. As directed by section 6015(f), the Commissioner has prescribed guidelines under which a taxpayer may qualify forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: March 27, 2008