Spouses who file a joint federal income tax return are generally jointly and severally liable for any tax reported as due on the return or any deficiency determined to be due with respect to a joint return. This rule can lead to inequitable results in a variety of situations, such as where the spouses are separated or divorced, where one spouse dies leaving unpaid tax liabilities or deficiencies, or where one spouse files a return without his or her spouse's consent.
This webinar, offered by a leading tax controversy attorney, will discuss:
(1) strategies to protect the innocent spouse prior to the filing of a return,
(2) the process to disavow a joint return already filed with the tax authorities,
(3) the rules related to obtaining innocent spouse relief under section 6015(b), (c), and (f) of the Internal Revenue Code,
(4) strategies to represent the putative non-innocent spouse, and
(5) ethical considerations for practitioners representing both spouses.
This webinar is a must-attend for practitioners who represent spouses who file joint returns.
Lawrence (“Larry”) Sannicandro is an associate in the Tax, Employee Benefits & Private Clients Practice Group who concentrates his practice on tax controversy and tax planning matters. He represents businesses, estates, trusts, and individuals at all stages of tax controversies, including in audits, before the IRS Office of Appeals, and in litigation before the United States Tax Court, the U.S. Court of Federal Claims, the U.S. District Courts, and the U.S. Courts of Appeals.