Income Tax Issues
Divorce

Leith v. Commissioner
T.C. Memo. 2020-149

On November 4, 2020, the Tax Court issued a Memorandum Opinion in the case Leith v. Commissioner (T.C. Memo. 2020-149). The primary issue before the court in Leith v. Commissioner was whether the petitioner is entitled to IRC § 6015(f) equitable innocent spouse relief to the extent of the tax items attributable to her ex-husband for the years at issue, even though her ex-husband (the intervenor) opposed the relief.

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Income Tax Issues
Dammit Felicia

Robinson v. Commissioner
T.C. Memo. 2020-134

On September 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Robinson v. Commissioner (T.C. Memo. 2020-134). The primary issue before the court in Robinson v. Commissioner was whether the petitioner was entitled to equitable relief from joint and several liability (innocent spouse relief) associated with a joint return from 2010.

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Procedural Issues
"Stand-Alone" Innocent Spouse Cases

Sutherland v. Commissioner
155 T.C. No. 6

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

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Income Tax Issues
Equitable Innocent Spouse Relief

Rogers v. Commissioner
T.C. Memo. 2020-91

On June 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Rogers v. Commissioner (T.C. Memo. 2020-91). The issue before the court in Rogers v. Commissioner was whether the petitioner-wife was eligible for innocent spouse relief pursuant to IRC § 6015(b), and, if not, whether she should be granted relief pursuant to IRC § 6015(f). A (Not So) Beautiful Day in the Neighborhood in Rogers v. Commissioner The petitioners, Mr. and

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Leith v. Commissioner
T.C. Memo. 2020-149

On November 4, 2020, the Tax Court issued a Memorandum Opinion in the case Leith v. Commissioner (T.C. Memo. 2020-149). The primary issue before the court in Leith v. Commissioner was whether the petitioner is entitled to IRC § 6015(f) equitable innocent spouse relief to the extent of the tax

Read More »

Robinson v. Commissioner
T.C. Memo. 2020-134

On September 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Robinson v. Commissioner (T.C. Memo. 2020-134). The primary issue before the court in Robinson v. Commissioner was whether the petitioner was entitled to equitable relief from joint and several liability (innocent spouse relief) associated with

Read More »

Sutherland v. Commissioner
155 T.C. No. 6

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

Read More »

Rogers v. Commissioner
T.C. Memo. 2020-91

On June 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Rogers v. Commissioner (T.C. Memo. 2020-91). The issue before the court in Rogers v. Commissioner was whether the petitioner-wife was eligible for innocent spouse relief pursuant to IRC § 6015(b), and, if not, whether she

Read More »