Where someone files files a joint return, Section 6015 of the Internal Revenue Code provides innocent spouse relief to help a taxpayer who did not know and did not have reason to know that his or her spouse understated or underpaid an income tax liability. There are basically three kinds of innocent spouse relief:
Our discussion deals with the time deadline changes for the third, equitable relief provision.
The Internal Revenue Service announced on July 25, 2011 that it will extend help to more innocent spouses by eliminating the two-year time limit that now applies to equitable relief requests under Section 6015(f). This change to the two-year limit is effective immediately. (Note: The two year rule still applies for the other two forms of relief under Sections 6015(b) and (c).) There have been numerous conflicting court cases on whether the two year rule applies to equitable relief under Section 6015(f). The IRS has acted to resolve this conflict and confusion so as to be seen as more sensitive to the plight of many of these abused, victimized and innocent taxpayers.
The IRS policies and procedures with respect to these changes are slated to become fully operational in the fall and additional guidance will be forthcoming from them. However, the recent announcement states as to equitable relief:
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Jonathan Weiss, November 11, 2008
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From their offices in Philadelphia, PA, the law firm of Steven J. Fromm & Associates, P.C. provides a full range of estate planning, probate and estate administration, tax, business and corporate legal services to clients throughout eastern Pennsylvania and the Delaware Valley, the Lehigh Valley Area, the Five-County Area, Bucks County, Delaware County, Montgomery County, Chester County, Philadelphia County, Berks County, Lehigh County, Lancaster County, York County, Harrisburg, Norristown, Doylestown, Media, West Chester, Allentown, Lancaster, and Reading.