Webinar: Till Debt Do Us Part: Innocent Spouse Relief Under Section 6015 by ALFi

Innocent spouse relief turns on which subsection applies, whether the request is timely, and what the practitioner presents to the IRS before a determination issues.

Presenters

Peter Haukebo

Partner

Peter Haukebo is a tax controversy attorney and Partner at Frost Law, where he represents clients in complex federal and state tax disputes. His practice includes handling IRS audits, appeals, and litigation with a particular focus on employment tax controversies and the Employee Retention Credit. Peter frequently presents to national audiences on tax procedure and controversy topics, blending technical insights with practical strategies. He is admitted to practice in Arizona and Maryland and before the United States Tax Court, Court of Federal Claims, Court of International Trade, and several District Courts. Peter previously taught in the Low Income Taxpayer Clinic at the University of Maryland School of Law and chaired the Taxation Section of the Maryland State Bar Association.

Rebecca Sheppard

Rebecca Sheppard is a Partner at Frost Law with extensive experience representing clients before the IRS and state taxing authorities. She advises on audits, appeals, and tax litigation, focusing on employment tax and the Employee Retention Credit. Rebecca is known for her practical, innovative approach to controversy work and her ability to translate complex tax issues into actionable guidance for practitioners. She regularly speaks on tax procedure and controversy topics to professional audiences. She is a member of the Maryland State Bar Association’s Taxation Section Council.

About

Program Field of Study: Taxes, Federal Tax Related Matters
Program Level: Basic
Who Should Attend: CPAs, Enrolled Agents, tax preparers, attorneys
Credits: 1 CPE | 1 CE
Advanced Preparation: None
Prerequisite: None
IRS Program Number: JWRXB-T-00037-26-O

This course walks through the three routes to relief under IRC §6015 — understatement relief under (b), allocation of a deficiency under (c), and equitable relief under (f) — and the distinct eligibility, knowledge, and refund rules attached to each. It covers the filing clocks that govern Form 8857, the collection and refund periods that replace the old two-year rule for equitable relief, and the 90-day standalone petition deadline the Tax Court has held jurisdictional. Attendees will also examine how abuse and financial control affect the analysis, what belongs in the administrative record under §6015(e)(7), and how recent decisions—including Thomas, Frutiger, and Sleeth—shape case development. Two client fact patterns tie the framework to the evidence and deadlines a practitioner must address at intake.

Agenda

Identify the appropriate route to relief under IRC §6015(b), (c), or (f) based on the type of liability and the client's marital status
Calculate the filing, collection, refund, and Tax Court deadlines that apply to an innocent spouse request and distinguish the trigger for each
Develop the administrative record and supporting evidence needed before the IRS issues a determination
Evaluate how abuse and financial control affect the knowledge analysis and the equitable factors under Rev. Proc. 2013-34
Apply recent Tax Court decisions to common client fact patterns involving unpaid reported tax and omitted-income deficiencies