Lois Lipton - Page 9

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          the return or found to be owing.  Sec. 6013(d)(3).  In certain              
          situations, however, a joint return filer can avoid such joint              
          and several liability by qualifying for relief therefrom under              
          section 6015.                                                               
          Relief Available Under Section 6015(f)                                      
               Section 6015 provides relief from joint liability by                   
          providing the taxpayer with three avenues for obtaining relief:             
          (1) Section 6015(b) provides full or apportioned relief with                
          respect to understatements of tax attributable to certain                   
          erroneous items on the return; (2) section 6015(c) provides                 
          relief for a portion of an understatement of tax for taxpayers              
          who are separated or divorced; and (3) section 6015(f)                      
          (potentially the broadest of the three avenues and the avenue               
          pertinent to the issue in this case) confers upon the Secretary             
          discretion to grant equitable relief for taxpayers who otherwise            
          do not qualify for relief under section 6015(b) or (c).  As there           
          is no understatement of tax at issue, neither section 6015(b) nor           
          (c) applies.  Therefore, we must consider the equitable relief              
          provisions of section 6015(f).                                              
               Section 6015(f), as amended, provides, in part, that a                 
          taxpayer may be relieved from joint and several liability if it             
          is determined that, taking into account all the facts and                   
          circumstances, it is inequitable to hold the taxpayer liable for            
          the unpaid tax, and relief is not available under section 6015(b)           






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