IRS Innocent Spouse Tax Relief: A Treatise for Attorneys, CPAs & Tax Preparers offers tax professionals a scholarly treatise on the IRS program that relieves a requesting spouse (or former spouse) from joint and several tax liability. Innocent spouse relief is offered on equitable grounds or when the tax is attributable to a non-requesting spouse’s bad behavior – including fraud, income concealment, income misstatement, and unwarranted expense deductions or tax credits. This book offers a deep dive into the U.S. Tax Code, Treasury regulations, court opinions, the Internal Revenue Manual, and IRS Revenue Procedures that comprise the IRS’ Innocent Spouse Tax Relief program. This is a resource book for tax professionals. Congress authorized relief to the “innocent” spouse who would otherwise be inequitably harmed by the non-requesting spouse. The three types of relief from joint and several tax liability are analyzed with relevant citations to the U.S. Tax Code, Treasury regulations, court opinions, the Internal Revenue Manual, and IRS Revenue Procedures. A separate discussion is presented for Innocent Spouse Relief, Separation of Liability Relief, and Equitable Relief, including a line-by-line analysis of IRS Form 8857, Request for Innocent Spouse Relief. An 8-page Table of Contents, a 19-page Table of Authorities, and a 9-page Index aids a tax professional’s scholarly understanding. The book also explores premature and untimely relief claims, appellate review of rejected claims, and refund claims after relief is granted. IRS Innocent Spouse Tax Relief: A Treatise for Attorneys, CPAs & Tax Preparers also explores the IRS collection process with a discussion of IRS levies, tax liens, installment agreements, the offer in compromise program, and currently not collectible status. Finally, powers of attorney and third-party authorizations are examined, including a line-by-line analysis of IRS Form 2848, Power of Attorney and IRS Form 8821, Tax Information Authorization.
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