This week, the IRS issued proposed regulations that would make permanent rules to extend the amount of time taxpayers can apply for equitable relief through an innocent spouse application. Under the proposed rules, taxpayers would have up to ten years – or generally, the same time frame as IRS has to collect – to file for equitable relief. If the taxpayer is making a claim for refund, the statute of limitations for refund would apply. If approved, the regulations will be considered effective as of the date of Notice 2011-70 which means that they would apply to applications for innocent spouse relief filed on or after July 25, 2011. See proposed REG-132251-11 here.