Innocent Spouse Relief

Innocent spouse relief provides relief from joint and several tax liability when a spouse or ex-spouse improperly reported items on a joint return. Three types exist: innocent spouse relief (Section 6015(b)), separation of liability (Section 6015(c)), and equitable relief (Section 6015(f)).

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Exam Tip

Three types: innocent spouse (6015(b)), separation of liability (6015(c)), equitable relief (6015(f)). Must have filed jointly. Form 8857. 2-year deadline from first collection activity.

What is Innocent Spouse Relief?

When filing jointly, both spouses are jointly and severally liable for the entire tax. Innocent spouse relief provides an escape when one spouse was unaware of errors.

Three Types of Relief

TypeSectionKey Requirements
Innocent Spouse6015(b)Didn't know/had no reason to know of understatement
Separation of Liability6015(c)Divorced, separated, or lived apart 12+ months
Equitable Relief6015(f)Doesn't qualify for other types but inequitable to hold liable

Innocent Spouse Relief Requirements (6015(b))

RequirementDetails
Joint return filedMust have filed jointly
UnderstatementDue to erroneous items of other spouse
No knowledgeDidn't know and had no reason to know
InequitableUnfair to hold requesting spouse liable

Filing Deadline

TypeDeadline
Innocent spouse (b)Within 2 years of first collection activity
Separation of liability (c)Within 2 years of first collection activity
Equitable relief (f)Collection statute expiration or 2 years from last refund credit

Exam Alert

Three types of innocent spouse relief. Must have filed JOINTLY. Section 6015(b) = didn't know about errors. Section 6015(c) = now divorced/separated. Section 6015(f) = catch-all equitable relief. File Form 8857. Two-year deadline from first collection activity for (b) and (c).

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