Innocent spouse relief.
In her 2006 annual report, Nina Olson, the National Taxpayer Advocate, included innocent spouse cases as among the most litigated; see National Taxpayer Advocate's 2006 Annual Report to Congress, at www.irs.gov/advocate/article/0,,id=165806,00.html.
An analysis of recent cases reveals that the Service interprets the rules as narrowly as possible. This is especially true of the "equitable" relief cases using Sec. 6015(f), which Congress intended for cases that do not fit the other two forms of innocent spouse protection: innocent spouse relief and relief by separation of liability.
FROM CAROL MARKMAN, CPA, FELDMAN, MEINBERG & CO. LLP, SYOSSET, NY
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|Title Annotation:||Tax Practice & Procedures|
|Publication:||The Tax Adviser|
|Date:||Apr 1, 2007|
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