Tax News

CCH (cch.taxgroup.com) reports:

The IRS abused its discretion in denying an individual equitable relief from joint and several liability under Code Sec. 6015(f). Most of the factors in section 4.03 of Rev. Proc. 2003-61, 2003-2 CB 296, either favored granting her relief or were of neutral impact.
Although the taxpayer had constructive knowledge of the taxes due because she signed the returns, the liabilities reported on those returns were solely attributable to her husband, who exercised absolute control over all the couple's financial matters. Further, the taxpayer derived no significant benefit from the failure to pay the tax liabilities for the years at issue and she would suffer ever greater economic hardship than already existed if forced to pay the outstanding tax liability.
C.K. Beatty, TC Memo. 2007-167, Dec. 56,984(M)
Other References:
Code Sec. 6015
CCH Reference - 2007FED ¶35,192.25
Tax Research Consultant
CCH Reference - TRC INDIV: 18,058
CCH Reference - TRC INDIV: 18,058.05
CCH Reference - TRC INDIV: 18,058.10
CCH Reference - TRC INDIV: 18,058.15