- Instructor: Attorney Bob Schaller
- Lectures: 7
- Quizzes: 1
Equitable Tax Relief.
Congress has authorized “Equitable Relief” for qualifying spouses to relieve them from certain joint and several tax liability related to a tax deficiency and/or underpayment. 26 U.S.C. § 6015(f). Equitable Relief also applies to penalties and interest when relief is granted for the underlying item. IRM § 25.15.12.20.3(5) (10-28-2014). Equitable Relief may be granted from a fraud penalty. See Aranda v. Comm. of Internal Revenue, 432 F.3d 1140, 1143 (10th Cir. 2005). Unlike Innocent Spouse Relief and Separation of Liability Relief, Equitable Relief is the only relief offered by 26 U.S.C. § 6015 that could eliminate both deficiency and underpayment tax liability shown on a taxpayer’s IRS Form 1040. Innocent Spouse Relief and Separation of Liability Relief are limited to tax deficiency liability.
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Overview
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Ineligibility for Equitable Relief
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Eligibility for Equitable Relief
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7 Conditions for Equitable Relief
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Exceptions for Tax Otherwise Attributable to Requesting Spouse
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Streamlined Determinations Granting Equitable Relief
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Full Determination for Granting Equitable Relief
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Quiz
Reviews
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Tax Law
This course teaches tax professionals that Congress has authorized “Equitable Relief” for qualifying spouses to relieve them from certain joint and several tax liability related to a tax deficiency and/or underpayment. Equitable Relief also applies to penalties and interest when relief is granted for the underlying item. Equitable Relief may be granted from a fraud penalty. Unlike Innocent Spouse Relief and Separation of Liability Relief, Equitable Relief is the only relief offered by 26 U.S.C. § 6015 that could eliminate both deficiency and underpayment tax liability shown on a taxpayer’s IRS Form 1040. Innocent Spouse Relief and Separation of Liability Relief are limited to tax deficiency liability.
