Ca. Tax Lawyer August 2018, Volume 27, Number 2

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.


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