On September 8, 2020, the Tax Court issued its opinion in Sutherland v. Commissioner (155 T.C. No. 6). The primary issues presented in Sutherland v. Commissioner were whether IRC § 6015(e)(7) applied to a petition filed prior to July 1, 2019, and whether remand to appeals in a standalone innocent spouse case to allow the petitioner to present additional evidence was appropriate. Changes to Innocent Spouse Statute under Taxpayer First Act in Sutherland v. Commissioner The Taxpayer First Act (Act), 133 Stat. at 988 (2019), added IRC § 6015(e)(7) and IRC § 6015(f)(2). IRC § 6015(e)(7) addresses the scope and standard of our review in stand-alone innocent spouse cases, while IRC § 6015(f)(2) sets forth a limitation on the IRS’s authority to grant requests for equitable relief. Congress specified that the amendments effected by § 1203(b) of the Act, which addressed the innocent spouse additions, applied to petitions or requests…