Docket No. 16-3034 August Term 2016.

862 F.3d 192 (2017)

Linda Jean MATUSZAK, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided: July 5, 2017.

Attorney(s) appearing for the Case

JEFFREY ZINK , Federal Tax Clinic, Harvard Law School, Jamaica Plain, MA ( T. Keith Fogg , Federal Tax Clinic, Harvard Law School, Jamaica Plain, MA; Carlton M. Smith , New York, NY, on the brief), for Petitioner-Appellant.

RICHARD CALDARONE , Attorney, Tax Division ( Diana L. Erbsen , Deputy Assistant Attorney General, Gilbert S. Rothenberg , Francesca Ugolini , Attorneys, Tax Division, on the brief), for Caroline D. Ciraolo , Principal Deputy Assistant Attorney General, Washington, D.C., for Respondent-Appellee.

Before: CALABRESI, WESLEY, and LOHIER, Circuit Judges.

The Internal Revenue Code generally holds spouses jointly and severally liable for the entire tax due on a joint return. See I.R.C. § 6013(d)(3). Section 6015 creates several exceptions to that rule. It relieves a spouse of joint and several liability in certain circumstances in which the other spouse fails to report income or reports...


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