Tag Archives: EQUITABLE RELIEF

UNFAIRNESS TO FORMER SPOUSE IN PAYING TAX LIABILITY OF FORMER HUSBAND IS NOT A FACTOR IN INNOCENT SPOUSE EQUITABLE RELIEF WHEN JOINT RETURN WAS FILED

Posted on August 22, 2013 by steinbergtaxlaw

O’Neil v. Commissioner T.C. Memo 2012-339 is a good innocent spouse case to read.  Without going into all of the dreary details, the bottom line is that the parties were married and then divorced.  While they were estranged and still separated, … Continue reading →

Posted in DIVORCE, EQUITABLE RELIEF, INNOCENT SPOUSE, JOINT RETURNS, TAX | Tagged , , , , , | 2 Comments

IRS PR0POSED NEW RULES FOR DETERMINING IF SPOUSE QUALIFIES FOR EQUITABLE RELIEF UNDER IRC SECTION 6015(f)

Posted on October 4, 2012 by steinbergtaxlaw

INNOCENT SPOUSE MUCH LITIGATED One of the most litigated issues in Tax Court is an appeal from an IRS final determination that a spouse is not eligible for so-called “innocent spouse relief.”  “Innocent Spouse” is a phrase commonly used to refer … Continue reading →

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INNOCENT SPOUSE CASE OF THE MONTH – AUGUST 2012 -CATHERINE MARIE NUMEZ f/k/a CATHERINE MARIE URIARTE, AND ROBERT URIARTE, INTERVENOR, V. COMM’R T.C. MEMO 2012-1212 (APRILS 25, 2012)

Posted on August 18, 2012 by steinbergtaxlaw

This decision once again illustrates the problems and procedural machinations that arise from a spouse’s right to intervene in Tax Court proceedings when the other spouse requests relief from joint and several liabilities under any of three escape hatches afforded … Continue reading →

Posted in DIVORCE, EQUITABLE RELIEF, INNOCENT SPOUSE, IRS COLLECTIONS, JOINT RETURNS, TAX, TAX LITIGATION, Uncategorized | Tagged , , , , , | Leave a comment

DOCTRINE OF RES JUDICATA BARRED RE-LITIGATING INNOCENT SPOUSE CLAIM FOLLOWING IRS CHANGE IN POLICY REGARDING 2 YEAR LIMITATION PERIOD FOR BRINGING EQUITABLE RELIEF CLAIM UNDER IRC SEC. 6015(f)

Posted on July 19, 2012 by steinbergtaxlaw

In Haag v. Shulman, (Case 11-1979, July 2, 2012), the First Circuit Court of Appeals upheld the Tax Court’s decision that Kathleen Haag (Haag) was not entitled to renew her innocent spouse claim for relief from joint and several liability … Continue reading →

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INNOCENT SPOUSE CASE OF THE MONTH – FEBRUARY, 2012: WHAT WAS THIS SPOUSE THINKING?

Posted on March 3, 2012 by steinbergtaxlaw

The Innocent Spouse case of the month is Ladehoff v Commissioner, T.C. Summary Opinion 2012-15 (February 27, 2012).  This case was heard under the Small tax case procedures, elected by the petitioner under Section 7463, and may not be cited … Continue reading →

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INNOCENT SPOUSE CASE OF THE MONTH: WHAT WAS IRS THINKING?

Posted on February 1, 2012 by steinbergtaxlaw

The Innocent Spouse case of the month is Wickman  v. Commissioner, T.C. Summary Opinion 2012-8 (January 25, 2012).  This case was heard under the Small tax case procedures, elected by the petitioner under Section 7463, and may not be cited as … Continue reading →

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