
- Instructor: Attorney Bob Schaller
- Lectures: 12
- Quizzes: 1
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 (income taxes) exceeds the tax amount shown on the taxpayer’s IRS Form 1040 return. 26 U.S.C. § 6211(a). The procedures to separate liability are set forth in 26 U.S.C. § 6015(c) and Rev. Proc. 2013-34.
Overview
Condition 1: Timely Filed Election
Condition 2: Joint Tax Return
Condition 3: Marital Status
Burden of Proof: Requesting Spouse
One Spouse Attributed to Erroneous Item
Both Spouses Attributed to Erroneous Item
IRS 7 Steps to Allocate Understatements
Limitations on Relief: General
Limitations on Relief - Actual Knowledge
Limitations on Relief - Transfer of Property to Avoid Tax
Refund Eligibility
Quiz
Reviews
Tax Law
This course teaches tax professionals that 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.” The Tax Code defines “deficiency,” generally, as the amount by which the tax imposed by IRS Subtitle A (income taxes) exceeds the tax amount shown on the taxpayer’s IRS Form 1040 return.