Wilson v. CIR

Petitioner sought innocent spouse relief, claiming that she did not understand the nature of her husband's business and claiming ignorance of his fraudulent actions regarding his tax liabilities. At issue was how the Tax Court should review appeals for equitable innocent spouse relief from joint and several liability for unpaid taxes under 26 U.S.C. 6015(f). The court joined the Eleventh Circuit and held that the Tax Court properly considered new evidence outside the administrative record. The court also concluded that the Tax Court correctly applied a de novo standard of review in determining the taxpayer's eligibility for equitable relief. Accordingly, the court affirmed the Tax Court's judgment. View "Wilson v. CIR" on Justia Law