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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.
LEXIS.com users can view the enhanced version of Lantz v. Comm'r, 2010 U.S. App. LEXIS 11604 (7th Cir. June 8, 2010).
You can also use the lexisOne Free Case Law search to view the free, unenhanced version of Lantz v. Comm'r, 2010 U.S. App. LEXIS 11604 (7th Cir. June 8, 2010).