In the first part of this article, I discussed the availability of relief for a taxpayer from liability for tax on a joint return that results from his or her spouse's errors or omissions, focusing on the equitable catch-all provided in IRC ' 6015(f).
Equity and Relief from Joint Return Liabilities
In the first part of this article, the author discussed the availability of relief for a taxpayer from liability for tax on a joint return that results from his or her spouse's errors or omissions, focusing on the equitable catch-all provided in IRC ' 6015(f). In December 2006, Congress amended the statute explicitly to provide for Tax Court review of IRS determinations not to grant relief under ' 6015(f). Now, the author considers how the Tax Court evaluates these claims in relation to the position of the IRS.
By
Thomas R. White, 3rdThis premium content is locked for LawJournalNewsletters subscribers only
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