Innocent Spouse Relief Under IRC Section 6015

Navigating New Tax Rules to Avoid Liability for Divorced, Widowed or Married Clients

Recording of a 110-minute premium CLE/CPE webinar with Q&A

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Conducted on Tuesday, March 13, 2012

Recorded event now available

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Course Materials

This teleconference will provide tax advisors with a review of the scope and elements of the innocent spouse relief rule, filing requirements, and the administrative and appeals process.


Innocent spouse tax relief can shield one spouse from liability for taxes, penalties and interest that the IRS later determines is owed from a joint filing. IRC Section 6015 allows relief for situations where it would be unfair to hold an “innocent” spouse liable for this tax responsibility.

While the innocent spouse rules can be complex, the IRS has taken steps to ease the burden on some taxpayers seeking innocent spouse relief. In July 2011, the IRS eliminated the 2-year time limit to request relief.

In Jan. 2012, the IRS released new proposed guidelines designed to provide relief to more innocent spouses requesting equitable relief from income tax liability. The guidelines revise threshold requirements for requesting relief and revise the factors the IRS will now use to evaluate requests.

Listen as our authoritative panel of tax counsel offers guidance in navigating the innocent spouse relief rule and provides best practices for obtaining relief for your client.



  1. Innocent Spouse Relief
    1. Basic innocent spouse relief
    2. Separate liability election
    3. Equitable relief
    4. Ethical/conflicts issues
  2. IRS Notice 2012-8
    1. Recognizing spousal abuse
    2. Recognizing substance abuse
  3. Filing requirements; administrative process through IRS Appeals
    1. Form 8857
    2. IRS Notice 2011-70
    3. Tax court review


The panel will review these and other key questions:

  • What pitfalls must counsel be cognizant of in assisting clients in completing Form 8857?
  • How can taxpayers who were previously denied relief take advantage of the elimination of the 2-year limitation period?
  • What questions should counsel ask a client who is facing tax liability from a joint return filed by a current or former spouse?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Pietro E. Canestrelli
Pietro E. Canestrelli

Reid & Hellyer

With over 12 years of tax law controversy experience, he has saved clients millions in taxes, penalties and interest. ...  |  Read More

Stephen J. Dunn
Stephen J. Dunn

DUNN Counsel

Mr. Dunn represents entrepreneurs and much of his work involves civil tax controversies. These include research...  |  Read More

Scott A. Schumacher
Scott A. Schumacher

Associate Professor of Law
University of Washington School of Law

He teaches courses in the Graduate Program in Taxation and is the Director of the Law School's Federal Tax Clinic....  |  Read More

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