Equal Protection Problem in Innocent Spouse Procedures

Date

2006

Authors

Camp, Bryan T.

Journal Title

Journal ISSN

Volume Title

Publisher

Tax Notes

Abstract

Professor Camp argues that there is an equal protection problem in innocent spouse procedures because of the interaction of the full-pay rule, the CDP mash-up rule, and the jurisdictional rule in IR Code ยง 6015(e). He further argues that this problem can easily be fixed.

Description

Keywords

Collection due process, CDP, Tax administration, Tax court

Citation

112 Tax Notes 281