- 30 - 6. Attributable to Nonrequesting Spouse In recommending that petitioner be granted partial relief from liability, the Appeals officer erroneously computed petitioner’s liability under the community property rules. Determinations under section 6015 are to be made without regard to community property. Sec. 6015(a); Mora v. Commissioner, 117 T.C. at 290 n.8. Respondent contends that, on the basis of the information before the Appeals officer, the officer properly allocated the liabilities equally between petitioner and Mr. Scott. Respondent complains that without more information from petitioner respondent could not tell whose income was reported on the returns. Respondent urges that, given the fact that for all 6 years at issue both petitioner and Mr. Scott had wages and self- employment income, the Appeals officer’s determination of a 50- percent allocation was appropriate under the circumstances. We disagree. The Forms W-2, Wage and Tax Statement, attached to the returns show that Mr. Scott’s income greatly exceeded petitioner’s for every year at issue. Mr. Scott handled the family finances and dominated the family. He told petitioner the number of exemptions to claim for withholding. He was an accountant, and petitioner believed that the claimed exemptionsPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 NextLast modified: November 10, 2007