Part One of this Note details the historical background of joint and several liability in federal income taxation. Part Two introduces, compares, and contrasts the two statutory provisions Congress has enacted to relieve “innocent spouses” from joint and several liability. Part Three discusses the incongruent standards of review applied by the Tax Court to these—§§ 66 and 6015—two substantially similar relief provisions. Finally, Part Four suggests remedies to alleviate this incongruity.
Jason Harn, De Novo: Reviewing Tax Court Redressability Incongruities in Innocent Spouse Relief Sections 66© and 6015(f), 41 SEATTLE U. L. REV. 1189 (2018).