Traces how the author learned after her husband's sudden death that he owed millions of dollars in taxes to the IRS and that she was going to be held liable or even imprisoned, and recounts her long journey toward recovery and independence.

By law, married persons who file joint tax returns are each fully responsible for the accuracy of the tax return and for the full tax liability. This is true even though only one taxpayer may have earned the wages or income shown on the tax return. Under the Internal Revenue Services (IRS) Innocent Spouse Program, IRS can relieve taxpayers of tax debts on the basis of equity considerations, such as not knowing that their spouse failed to pay taxes due. Since passage of the IRS Restructuring and Reform Act (Restructuring Act) of 1998, IRS has received thousands of requests from taxpayers for innocent spouse relief. IRSs inability to provide timely responses to such requests has generated concerns among taxpayers, Congress, and other stakeholders. It took IRS about a year, on average, to completely process an innocent spouse case in fiscal year 2001.

Attorney Robert Schaller and the Schaller Law Firm offer IRS Innocent Spouse Tax Relief to tax professionals. This book is a scholarly treatise on the IRS program that relieves a requesting spouse (or former spouse) from joint and several tax liability. Innocent spouse relief is offered on equitable grounds or when the tax is attributable to a non-requesting spouse’s bad behavior – including fraud, income concealment, income misstatement, and unwarranted expense deductions or tax credits. This book offers a deep dive into the U.S. Tax Code, Treasury regulations, court opinions, the Internal Revenue Manual, and IRS Revenue Procedures that comprise the IRS’ Innocent Spouse Tax Relief program. This is a resource book for tax professionals. Congress authorized relief to the “innocent” spouse who would otherwise be inequitably harmed by the non-requesting spouse. The three types of relief from joint and several tax liability are analyzed with relevant citations to the U.S. Tax Code, Treasury regulations, court opinions, the Internal Revenue Manual, and IRS Revenue Procedures. A separate discussion is presented for Innocent Spouse Relief, Separation of Liability Relief, and Equitable Relief, including a line-by-line analysis of IRS Form 8857, Request for Innocent Spouse Relief. An 8-page Table of Contents, a 19-page Table of Authorities, and a 9-page Index aides a tax professional’s scholarly understanding. The book also explores premature and untimely relief claims, appellate review of rejected claims, and refund claims after relief is granted. IRS Innocent Spouse Tax Relief also explores the IRS collection process with a discussion of IRS levies, tax liens, installment agreements, the offer in compromise program, and currently not collectible status. Finally, powers of attorney and third-party authorizations are examined, including a line-by-line analysis of IRS Form 2848, Power of Attorney and IRS Form 8821, Tax Information Authorization.

The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.