The Fourth Circuit reversed the Tax Court and joins with the Third and Seventh Circuits upholding Reg. 1.6015-5(b)(1), which proves that a spouse must request equitable relief under Code Sec. 6015(f) no later than two years from the first collection activity against the spouse in Jones v. Comm., (CA 4 6/13/2001) 107 AFTR 2d 2011-930

IRS Commissioner Doug Shulman has directed the IRS to review the two-year period regulation noting that the courts are at odds over the two-year rule.

Margaret L. Cross-Beliveau, Esq., LL.M.

The Beliveau Law Group: Massachusetts | Florida | New Hampshire

The attorneys at The Beliveau Law Group provides legal services for estate planning (wills and trusts), Medicaid (planning and applications), probate (estate and trust administration), business law (formation and operation), real estate (residential and commercial), taxation (federal and state), and civil litigation (in connection with these practice areas). The law firm has offices and attorneys in Naples, Florida; Boca Raton, Florida; Danvers, Massachusetts; Waltham, Massachusetts; Quincy, Massachusetts; Manchester, New Hampshire and Salem, New Hampshire.