Fourth Circuit: Two-Year Limit for Spouse Relief Request Valid

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Reversing a U.S. Tax Court decision, the Fourth Circuit holds that the Treasury regulation that establishes a two-year limitation period to request innocent spouse relief from joint and several income tax liability is valid. The Tax Court ruled that Treasury Regulation Section 1.6015-5(b)(1) was invalid for reasons that the Tax Court had given earlier in the 2009 case of Lantz v. Commissioner.