IRCCourt RulingsJun 15, 2009
tio n
6015 (b) (1) (C) .
On the record before us, we find that petitioner has failed
to carry his burden of establishing that he is entitled to relief under . section 6015(b) for . his taxable year 2004 .
Section 6015(c )
Section 6015(c) provides in pertinent part :
SEC . 6015 . RELIEF FROM . JOINT AND SEVERAL LIABILIT…
IRCCourt RulingsSep 24, 2007
everal liability
by following the procedures established in section 6015 . Sec .
6015(a) .
A taxpayer may be entitled to relief under section 6015(b), (c), or (f), and, except as otherwise provided in section 6015,
the taxpayer bears the burden of proving her entitlement t o
relief . Rule 142(a) ; Alt v . Commissioner …
IRCCourt RulingsAug 16, 2005
…n filer can avoid
such joint and several liability by qualifying for relief
therefrom under section 6015.
6 Section 6015 provides three avenues for obtaining relief to
a taxpayer who has filed a joint return: (1) Section 6015(b)
provides full or apportioned relief with respect to
understatements of tax attributable to …
IRCCourt RulingsNov 25, 2008
…ssioner , 85 T .C . 527, 529 (1985) .
2 In this Court an individual has three ways to request sec .
6015(f) relief . First, when an individual petitions the Court to
redetermine a deficiency, the individual may allege as a n
affirmative defense that he or she is entitled to sec . 6015(f)
relief . Second, the individual…
IRCCourt RulingsAug 16, 2005
e enactment of sec. 6015,
relief from the imposition of joint and several liability for
spouses filing joint returns was available under sec. 6013(e). 119 T.C. 306, 311 (2002), affd. 101 Fed. Appx. 34 (6th Cir.
2004).
As a general rule, married taxpayers may elect to file a
joint Federal income tax return. Sec. 6013(a)…
T.C. Memo. 2019-145 — Jane M. Lassek, Petitioner and Michael E. Smith, Intervenor v. Commissioner IRCCourt RulingsOct 28, 2019
…issioner, 119 T.C. 306, 311 (2002),
a_f[d, 101 F. App'x 34 (6th Cir. 2004). I. Relief Under Section 6015(c) for 2011
One of the above-mentioned limited circumstances is set forth in section
6015(c). Upon the taxpayer's election of its application, section 6015(c) limits a
spouse's liability to the portion of the defici…
T.C. Memo. 2011-253 — George R. Ward, Petitioner and Victoria J. Ward, Intervenor v. Commissioner IRCCourt RulingsOct 31, 2011
returns were filed. Sec.
6015(d) (2), (3) (A); sec. 1.6015-3(d) (4) (ii), Income Tax Regs.
The 10-percent additional tax would have been allocated to George R. Ward, not Victoria J. Ward, if they had filed separate
returns. George R. Ward received the distribution. As the
recipient, he was the taxpayer who would have …
IRCCourt RulingsJan 2, 2020
lly separated or lived apart), the requirements of section 6015(c) are not
satisfied and we must look to subsections (b) and/or (f) in turn. Except as otherwise provided, the requesting spouse bears the burden of proving that he or
- 14 -
[*14] she is entitled to section 6015 relief. Rule 142(a); Alt v. Commissioner, 1…
IRCCourt RulingsOct 24, 2007
… taxable years 1998,
1999, and 2000 and assessed based on those returns, but not paid,
only section 6015(f) is applicable. See sec. 6015(b)(1) and
(c)(1); Washington v. Commissioner
, 120 T.C. 137, 146-147 (2003).
Section 6015(f) provides, in pertinent part, that a taxpayer
may be relieved of liability for any unpaid t…
IRCCourt RulingsOct 16, 2008
… of the tax consequences of an item giving rise to a
deficiency to satisfy her burden under section 6015(b)(1)(C) .
See Price v . Commissioner , 887 F .2d 959, 964 (9th Cir . 1989) ;
Hopkins v . Commissioner , 121 T .C . 73, 78 n .ll (2003) . Thus,
petitioner had reason to know of the understatement . She cannot
satisf…
IRCCourt RulingsJul 12, 2012
, and (2) relief is not available under section 6015(b) or (c). The Internal
Revenue Service (IRS) has prescribed guidelines for determining whether a requesting spouse qualifies for relief under section 6015(f). See Rev. Proc. 200361, 2003-2 C.B. 296 (effective for requests for section 6015(f) relief filed during or
a…
IRCCourt RulingsDec 29, 2008
…r v . Commissioner , 114 T .C . 276, 282
(2000) ; sec . 1 .6013-4(b), Income Tax Regs .
B . Section 6015(f) Equitable Relie f
Section 6015 provides relief from joint and several
liability in certain circumstances . As relevant here, if the
taxpayer does not qualify for relief under section 6015(b) or
(c), then the taxp…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
T.C. Memo. 2014-109 — Leslie J. Molinet Petitioner, and Michael F. Molinet, Intervenor v. Commissioner IRCCourt RulingsJun 9, 2014
t available to the
spouse under section 6015(b) or (c). Sec. 6015(f)(1) and (2).
Subsections (b) and (c) of section 6015 apply only in the case of "an understatement of tax" or "any deficiency" in tax, and do not apply in the case of
underpayments of tax reported on joint tax returns. Sec. 6015(b)(1)(B), (c)(1);
Hopkin…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
PBGCRegulationsJul 1, 2019related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]