Cheryl Kunsman - Page 8

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               We are satisfied that petitioner filed a joint Federal                 
          income tax return for 1999.                                                 
               Each spouse filing a joint return is jointly and severally             
          liable for the accuracy of the return and for the entire tax due            
          for that year.  Sec. 6013(d)(3).  A spouse who has filed a joint            
          return may, however, seek relief from joint and several liability           
          by following the procedures established in section 6015.  Sec.              
               A taxpayer may be entitled to relief under section 6015(b),            
          (c), or (f), and, except as otherwise provided in section 6015,             
          the taxpayer bears the burden of proving her entitlement to                 
          relief.  Rule 142(a); Alt v. Commissioner, 119 T.C. 306, 311                
          (2002), affd. 101 Fed. Appx. 34 (6th Cir. 2004).                            
               With respect to elections under section 6015(b) and (c),               
          section 6015(e) grants this Court jurisdiction “to determine the            
          appropriate relief available”.  In contrast, we review denial of            
          relief under section 6015(f), which permits the Commissioner to             
          grant equitable relief, for abuse of discretion.  Fernandez v.              
          Commissioner, 114 T.C. 324, 330-333 (2000); Butler v.                       
          Commissioner, 114 T.C. 276, 292 (2000).                                     
               Section 6015(b)                                                        
               Section 6015(b)(1) provides for relief from liability for              
          tax attributable to an understatement if all five conditions set            
          out in section 6015(b)(1)(A) through (E) are satisfied.                     

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