Taxation
Ca. Tax Lawyer August 2018, Volume 27, Number 2
Content
- A Look at the Procedures Governing California Office of Tax Appeals Proceedings
- Are Corporate Investors Doing Business in California If They Invest in California Llcs? a Look at Swart
- Contents
- Masthead
- Message from the Chair
- Request for Guidance Regarding the Relevancy Requirement of the Check-the-Box Regulations
- Tax Business Taxation Section Overview
- Taxation Section 2017—2018 Leadership Directory
- Visiting the Committees
- Two Easy Fixes That Could Expand Eligibility for § 6015 Relief from Joint & Several Liability (Even While Retaining Current Rigorous Qualification Vetting)
Two Easy Fixes That Could Expand Eligibility for § 6015 Relief from Joint & Several Liability (Even While Retaining Current Rigorous Qualification Vetting)
By Robert S. Horwitz & Carolyn M. Lee1
- Extend the statute of limitations for claiming innocent spouse relief for § 6015(b) and § 6015(c), making all § 6015 forms of relief co-terminus with the § 6502 collection statute.
- Clarify and codify the standard and scope of judicial review of § 6015(b), § 6015(c) and § 6015(f).
The Taxpayer First Act (HR 5444) includes many provisions benefitting taxpayers, including Section 11303 addressing IRC § 6015, governing relief from joint and several liability for qualifying requesting spouses. The bill is that rare thing: Legislation with bipartisan support. The Taxpayer First Act was passed by the House of Representatives on April 18, 2018 by a vote of 414 to 0. It currently is pending in the Senate. The moment is now to refine HR 5444 to expand eligibility for § 6015 relief, even while retaining the current rigorous qualification vetting.