- 7 - jurisdiction to review the Commissioner’s determinations under section 6015(f) with respect to tax liability remaining unpaid on or after December 20, 2006. Upon order of the Court, the parties certified that petitioner’s liability for tax years 1998 and 1999 remained unpaid as of December 20, 2006.4 Accordingly, the Court determined that it has jurisdiction over this case and denied respondent’s motion to dismiss for lack of jurisdiction. OPINION If a husband and wife file a joint Federal income tax return, they generally are jointly and severally liable for the tax due. Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C. 276, 282 (2000). However, a spouse may qualify for relief from joint and several liability under section 6015(b) or (c) if various requirements are met. The parties agree that petitioner does not qualify for relief under section 6015(b) or (c). If relief is not available under section 6015(b) or (c), the Commissioner may relieve an individual of liability for any unpaid tax if, taking into account all the facts and circumstances, it would be inequitable to hold the individual liable. Sec. 6015(f). This Court has jurisdiction to review a denial of equitable relief under section 6015(f). Sec. 6015(e); 4 Petitioner’s 1997 tax year is no longer at issue. See supra note 3.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007