Two-Year Limitation No Longer Applies to Many Innocent Spouse Relief Requests

The IRS will be revising regulations under Code Secection 6015 so that individuals who request equitable relief under Code Sec. 6015(f) will no longer be required to submit the request within two years of the IRS's first collection activity against the requesting spouse with respect to the joint tax liability.

Until the regulations have been modified, individuals may rely on Notice 2011-70. The notice expands the period within which individuals may request equitable relief from joint and several liability under section 6015(f) of the Internal Revenue Code.

Posted by Brian Spring, Associate Editor, Wealth Strategies Journal.