The United States Tax Court (hereinafter, “Tax Court”) recently issued three seminal opinions1 regarding innocent spouse relief pursuant to Section 6015 of the Internal Revenue Code (hereinafter, “Code”). Each decision helped clarify relief under Code Section 6015(f), commonly referred to as “equitable relief.” Background When married taxpayers file a joint Form 1040 income tax return, [...]

When married taxpayers elect to file a “Married Filing Joint” tax return, both taxpayers are responsible for the accuracy of the income and other items reported on the tax return. So, what happens if a taxpayer who filed a joint return is later in a situation where there is tax owing, but the tax is [...]