OPINION
NIEMEYER, Circuit Judge:
This case presents the question of whether Treasury Regulation § 1.6015-5(b)(1), 26 C.F.R. § 1.6015-5(b)(1), establishing a two-year limitations period within which to request equitable innocent spouse relief from joint and several income tax liability under I.R.C. § 6015(f), is a valid regulation.
Robert and Octavia Jones filed a joint income tax return for the year 2000. After they legally separated...
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