The Seventh Circuit Court of Appeals reversed a divided Tax Court (132 T.C. No. 8 (Apr. 7, 2009)) decision by upholding the Treas. Reg. 1.6015-5(b)(1) requirement that innocent spouse relief claims (Form 8857) must be made no later than two years after IRS collection action begins, notwithstanding that IRC Sec. 6015(f), which governs innocent spouse claims, includes no such requirement.
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