- 3 - only $1,350, leaving a remaining tax of $2,633. The remaining amount does not include the interest and penalties that had been assessed or accrued. The deficiency of $3,983 is attributable to a disallowed earned income credit of $2,447, a $1,536 deficiency attributable to Mae E. Word’s unreported wages of $4,960, unreported gambling income of $3,400, and petitioner’s unreported pension income of $1,149. The parties agree that petitioner is entitled to relief of only $1,350 pursuant to section 6015(c). After application of section 6015(c), petitioner is liable for $2,404 in income tax for 1996.2 Further, after applying section 6015(c), respondent has conceded that there is no addition to tax pursuant to section 6651(a)(2). Discussion In general, spouses filing joint Federal income tax returns are jointly and severally liable for all taxes due. Sec. 6013(d)(3). Under certain circumstances, however, section 6015 provides relief from this general rule. Respondent has granted partial relief pursuant to section 6015(c). Petitioner remains liable for the tax attributable to the disallowed earned income credit and the unreported pension income and for the interest thereon. See Weiler v. Commissioner, T.C. Memo. 2003-255. 2 Petitioner had $229 of income tax withheld from his pension.Page: Previous 1 2 3 4 5 6 NextLast modified: March 27, 2008