Taxpayer losses.The Tax Court has supported the IRS's rulings against taxpayers in many equitable relief cases, including Madden mad·den v. mad·dened, mad·den·ing, mad·dens v.tr. 1. To make angry; irritate. 2. To drive insane. v.intr. To become infuriated. , TC Memo 2006-4, Motsko, TC Memo 2006-17, and Lopez, TC Memo 2005-36. The Tax Court denied relief even though the taxpayers in the cases might suffer economic hardship. The Tax Relief and Health Care Act of 2006 (TRAHCA '06) amended Sec. 6015 specifically to give the Tax Court jurisdiction to review innocent spouse cases claiming equitable relief and to suspend the statute of limitations A type of federal or state law that restricts the time within which legal proceedings may be brought. Statutes of limitations, which date back to early Roman Law, are a fundamental part of European and U.S. law. while such claims are pending. This provision may change the dynamic in some of these cases. Until the TKAHCA '06 was passed, Sec. 6015(e) gave taxpayers the option to petition the Tax Court to review denials of innocent spouse relief and relief by separation-of-liability cases, but not equitable relief cases. However, in Capehart, 11/7/06, the Ninth Circuit ruled that the Tax Court properly determined the taxpayer was not eligible for Sec. 6015 (b) relief from joint liabilities arising from tax shelter tax shelter: see tax exemption. investments, because she played a substantial role in managing the investments in question. FROM CAROL MARKMAN, CPA (Computer Press Association, Landing, NJ) An earlier membership organization founded in 1983 that promoted excellence in computer journalism. Its annual awards honored outstanding examples in print, broadcast and electronic media. The CPA disbanded in 2000. , FELDMAN, MEINBERG & CO. LLP LLP - Lower Layer Protocol , SYOSSET, NY |
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