- 14 -
Tax Year Liability Relief Allowed Liability Remaining
1990 $4,562.00 $2,281.00 $2,281.00
1991 4,874.00 2,437.00 2,437.00
1992 4,785.44 2,392.72 2,392.72
1993 3,692.44 1,846.22 1,846.22
1994 5,990.50 2,995.25 2,995.25
1995 1,387.00 693.50 693.50
The explanation of adjustments stated that respondent was
granting relief for the unpaid liability attributable to Mr.
Scott under the community property laws of California and Idaho
but could not grant full relief because of the “knowledge
factor”--petitioner had knowledge or reason to know that the
taxes would not be paid.
Discussion
As a general rule, spouses filing a joint Federal income tax
return are jointly and severally liable for all taxes shown on
the return or found to be owing. Sec. 6013(d)(3). Section 6015,
however, provides taxpayers relief from joint and several
liability under certain circumstances. Section 6015 encompasses
three types of relief: (1) Section 6015(b)(1) provides full or
apportioned relief from joint and several liability; (2) section
6015(c) provides proportionate tax relief to divorced or
separated taxpayers; and (3) section 6015(f) provides equitable
relief from joint and several liability in certain circumstances
if neither section 6015(b) nor (c) is available.
Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: November 10, 2007