- 6 - Petitioner reported wage income of $83,085 for 2005 and $89,354 for 2006. A total tax liability of approximately $5,007.83 remains unpaid for 1996, and approximately $2,872.41 remains unpaid for 1997. Discussion Except as otherwise provided in section 6015, petitioner bears the burden of proof with respect to her entitlement to relief under section 6015. See Rule 142(a); Alt v. Commissioner, 119 T.C. 306, 311 (2002), affd. 101 Fed. Appx. 34 (6th Cir. 2004). Joint and Several Liability and Section 6015 Relief Section 6013(d)(3) provides that if a joint return is filed, the tax is computed on the taxpayers’ aggregate income, and liability for the resulting tax is joint and several. See also sec. 1.6013-4(b), Income Tax Regs. But the IRS may relieve a taxpayer from joint and several liability under section 6015 in certain circumstances. To obtain relief from joint and several liability, a spouse must qualify under section 6015(b) or, if eligible, allocate liability under section 6015(c). In addition, if relief is not available under section 6015(b) or (c), a spouse may seek equitable relief under section 6015(f). Fernandez v. Commissioner, 114 T.C. 324, 329-331 (2000); Butler v. Commissioner, 114 T.C. 276, 287-292 (2000).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008