Innocent Spouse Relief Rules And Regulations

Webinar: ID# 1022835
Recorded CD
About This Course:
When couples get divorced, and even when they don't, one spouse is sometimes surprised to discover that they are on the hook financially for federal income tax liabilities that were incurred by the other spouse.

Sometimes this is because their spouse failed to pay an acknowledged tax liability on their jointly filed income tax return. In other instances this is the result of a tax audit, or other adjustment to the tax return by the Internal Revenue Service.

The innocent spouse provisions of the Internal Revenue Code may eliminate or reduce taxes, penalties, and interest for taxpayers who meet all of the requirements.

In 2012, the IRS reported that they received 32,000 new innocent spouse claims per year, and that only 22% received complete relief. This webinar will increase your batting average so that your clients will have a better chance of obtaining relief.


  • Why Innocent Spouse Relief May Be Necessary
  • Understanding the Terminology
  • Understanding the Joint Return Requirement
Meeting the Requirements of the Three Types of Innocent Spouse Relief
  • Traditional Innocent Spouse Relief
  • Spousal Allocation - Internal Revenue Code Section 6015(C)
  • Equitable Relief - Internal Revenue Code Section 6015(F)
Considerations in Representing the "Nonrequesting Spouse"
  • Conflict Issues
  • Intervening in an Innocent Spouse Case
Appeals of Denial of Innocent Spouse Claims
  • IRS Appeals Consideration
  • Tax Court
  • Non-Tax Court Litigation Alternatives
About The Presenters

Frank Agostino
  • President of Agostino & Associates, P.C., a law firm in Hackensack, New Jersey specializing in civil and white collar criminal litigation, tax controversies and tax planning
  • Prior to entering private practice, he was an attorney with the Internal Revenue Service’s District Counsel in Springfield, Illinois and Newark, New Jersey; he also served as a Special Assistant United States Attorney, where he prosecuted primarily criminal tax cases
  • Frequent speaker and author on tax controversy and litigation matters
  • Serves on the Advisory Board of the Journal of Tax Practice and Procedure; actively involved with the American Bar Association and the New York County Lawyers’ Association
  • President of the Taxpayers Assistance Corp., which provides tax and legal advice to low income taxpayers in the NY/NJ area
  • J.D. degree, New York Law School; B.A. degree, City College of New York; LL.M. degree in taxation, New York University School of Law
Dennis Brager
  • Founder of the Brager Tax Law Group – a worldwide practice limited to representing clients having criminal and civil disputes with the IRS, the California Franchise Tax Board, the State Board of Equalization and the Employment Development Department
  • Former Senior Trial Attorney for the Internal Revenue Service’s Office of Chief Counsel
  • California State Bar Certified Tax Specialist
  • Frequent lecturer at the UCLA Tax Controversy Institute and University of Southern California
  • Appeared on ABC’s Television show Good Morning America, Fox Business News, KFWB Money 101, and KABC’s The Larry Elder Show
  • Author of articles that have appeared in California Lawyer, Daily Journal, Taxation for Lawyers, Los Angeles Lawyer, The Consumer Advocate, Family Law News, California Tax Lawyer, Journal of Tax Practice and Procedure, Journal of Tax Investments, and Marijuana Venture
  • Quoted as a tax expert by Business Week, The Daily Journal, The Daily Beast, USA Today, Tax Analyst, The Chicago Tribune, CNN Money, Bloomberg BNA, Accounting Today, Tax Notes Today, and The National Law Journal
  • Former chair of both the Tax Compliance, Procedure and Litigation Committee of the Los Angeles County Bar Association and the California State Bar, Tax Procedure and Litigation Committee
Innocent Spouse Relief Rules And Regulations
Available on CD format
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