Lesley J. Smith, a.k.a. Lesley J. Scott - Page 15




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          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.                            








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