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ISR 103: Separation of Liability Relief
Separation of Liability Relief. Congress has authorized “Separation of Liability Relief” for qualifying spouses to relieve them from certain joint and several tax liability related to a tax “deficiency.” 26 U.S.C. § 6015(c). The Tax Code defines “deficiency,” generally, as the amount by which the tax imposed by IRS Subtitle A…
ISR 105: Form 8857, Request for Innocent Spouse Relief
IRS Form 8857, Request for Innocent Spouse Relief. A taxpayer seeks relief from joint and several liability by filing IRS Form 8857, Request for Innocent Spouse Relief. A Requesting Spouse may seek relief asserting one or more bases. A Requesting Spouse may submit a single claim (a) electing relief under…
ISR 106: Premature & Untimely Claims
Premature and Untimely Claims. A Requesting Spouse electing Innocent Spouse Relief and/or Separation of Liability Relief or requesting Equitable Relief must be cognizant of the window of opportunity. Elections and requests can neither be made prematurely nor untimely. Premature claims are discussed first, followed by a discussion of what constitutes…
ISR 107: Appellate Review
Appellate Review. This course discusses a Requesting Spouse’s appellate rights both (a) when the IRS fails to issue a “preliminary” determination within six (6) months of the election for Innocent Spouse Relief and/or Separation of Liability Relief, or request for Equitable Relief, and (b) after an IRS determination denying the…
ISR 108: Participation by Non-Requesting Spouse
Non-Requesting Spouse’s Participation. Conflict between the Requesting Spouse and the Non-Requesting Spouse is almost inevitable. Afterall, the Requesting Spouse is attempting to shift the joint and several tax burden onto the sole shoulders of the Non-Requesting Spouse. This burden shift request can make the Requesting Spouse unpopular in the eyes of…
ISR 109: Levies, Seizure & Court Proceedings Restricted
Levies, Seizure & Court Proceedings Restricted. The IRS’s ability to collect back-taxes is restricted when a Requesting Spouse files a claim with the IRS for Innocent Spouse Relief, Separation of Liability Relief, or Equitable Relief.
ISR 110: Installment Agreements
Installment Agreement Affected by Request for Relief. Some taxpayers do not know their tax options and contact the IRS for an installment agreement after receiving notice from the IRS that an audit revealed a tax deficiency due to a spouse’s failure to report income or improper deduction claim. This could be a…