In straightforward language, the third edition ofA Practitioner's Guide to Innocent Spouse Relieftakes you step-by-step through the innocent spouse claim process, from information gathering, to administrative proceedings, to determination, to trial, and to refund relief. It provides a comprehensive yet accessible guide for practitioners representing taxpayers in innocent spouse proceedings.
Since the 2014 edition, there have been important case law and administrative developments in the wake of Rev. Proc. 2013-34 as well as legislative changes to Section 6015 of the Internal Revenue Code. This edition incorporates updates in the Code, Tax Court and Circuit Court case law, and IRS practices, and alerts readers to important issues likely to be litigated over the coming years under the Taxpayer First Act of 2019.
This edition also offers three new chapters and substantial revisions to others:
"Meeting Your Client" provides expanded information and practical tips for successfully communicating a client's full circumstances to the IRS, including translating state law terms and proving spousal abuse. The chapter on tax court jurisdiction has become "Judicial Fora," expanding the book beyond the U.S. Tax Court and describing the possibilities for obtaining relief in other federal courts. A new chapter focused on community property states addresses the intersection of community property taxation and relief underI.R.C. 6015, and also guides the practitioner through relief from community property taxation underI.R.C. 66. Recognizing that an increasing number of states have adopted procedures for spousal relief from state tax liabilities, a new chapter summarizes relief available at the state level, to provide a starting point for practitioners. A chapter on collection alternatives rounds out the trio of new chapters and renders the book a more comprehensive resource.
