Freireich is a member of the wills, trusts and estates and litigation practice groups at Brach Eichler in Roseland. Kosicki is counsel to the firm in its wills, trusts and estates and??family law practice groups.
The Tax Court has provided hope for taxpayers seeking innocent spouse “equitable” relief under Internal Revenue Code §6015(f), even if the relief is sought more than two years after collection activity commenced. The Seventh Circuit had previously dashed taxpayer hopes by ruling that a claimant is barred if relief is requested more than two years after the commencement of collection activity. But the Tax Court has continued to permit taxpayers to obtain relief, undeterred by the Seventh Circuit’s ruling that no limitation exists at all.
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