The United States Tax Court Chief Judge Michael B. Thornton recently announced that the Tax Court has adopted interim amendments and has issued proposed amendments to the Tax Court Rules of Practice and Procedure relating to the Bipartisan Budget Act of 2015, the Fixing America's Surface Transportation Act, and the Protecting Americans from Tax Hikes Act of 2015. Among the proposed amendments to the Tax Court Rules are rules relating to the new ability of the IRS to issue a certification to the Secretary of State for action with respect to denial, revocation, or limitation of a passport in the case of "seriously delinquent tax debts." I.R.C. sec. 7345(a).
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.