This is the fourth article in a four part series addressing frequently asked questions relating to protection from joint and several liability in divorce. We are often asked about the language that a taxpayer’s attorney should include in the divorce decree to protect the taxpayer from joint and several tax liability. This series is intended [...]
This is the second article in a four part series addressing frequently asked questions related to protection from joint and several liability in divorce. We are often asked about the language that a taxpayer’s attorney should include in the divorce decree to protect the taxpayer from joint and several tax liabilities for only their spouse’s [...]
This is the first article in a series addressing frequently asked questions related to protection from joint and several tax liability in divorce. We are often asked about the language that a taxpayer’s attorney should include in the divorce decree to protect the taxpayer from joint and several tax liabilities resulting from only their spouse’s [...]
Tom recently presented a seminar to Minnesota attorneys in which he shared some common questions asked by clients dealing with tax controversies and explained how to help them. The questions Tom discussed include: Can I challenge the Internal Revenue Service’s (IRS) decision to pursue me for unpaid taxes? Can I get the IRS or the [...]
We often receive telephone calls and e-mails from individuals and businesses who have been contacted by the IRS for a tax obligation owing and they don’t know what to do. There are many options for dealing with these obligations. The correct option depends on the facts of the case. Unfortunately, too often, an individual or [...]
On January 5, 2012, in Notice 2012-8, the IRS significantly modified the rules for spouses seeking Innocent Spouse Relief under Internal Revenue Code Section 6015(f), which is also known as “Equitable Relief.” Notice 2012-8 is effective immediately and supersedes the old rules in Revenue Procedure 2003-61. The IRS will evaluate all new and pending Section [...]
On July 25, 2011, the IRS issued Notice 2011-70, stating that it will no longer deny a Request for Innocent Spouse Relief pursuant to Section 6015(f), “Equitable Relief,” on the basis that the claim was not submitted within two years of the date of the IRS’s first collection activity. The prior rule was stated in [...]