The IRS has Released Recommendations in Two Cases in an Actions Relating to Court Decisions Document Released in The Internal Revenue Bulletin

[Originally Published in the California Journal of Tax Litigation (August 2013)]
By Joseph P. Wilson
Wilson Acquiescence
The recommendation has been made that the IRS acquiesce in K.M. Wilson, U.S. Court of Appeals, Ninth Circuit; 10-72754, January 15, 2013, affirming the Tax Court, 99 TCM 155, TC Memo. 2010-134. The acquiescence relates to the appellate court’s holding that affirmed that the Tax Court properly considered new evidence and proceeded de novo to determine that an individual was eligible for equitable innocent spouse relief. The taxpayer requested equitable relief under Code Sec. 6015(f) from joint […]