Firm News – February 2012

Lead story:

Innocent Spouse Relief
Two Year Limitation Period No Longer Applicable in Certain Situations

By Nicholas Volk

Section 6015 of the Internal Revenue Code provides relief to a spouse or former
spouse from joint and several liability that normally results from signing a joint tax
return. One particular section allows the IRS to grant relief when the taxpayer is
otherwise ineligible for relief and when such relief would be equitable considering all
of the facts and circumstances. Over the years, the Internal Revenue Service
maintained the position that spouses seeking relief on equitable grounds must seek
such relief within 2 years after the IRS begins collection activities. The 2 year limit on
seeking relief is included in other sections of the statute, but not the section permitting
equitable relief…

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