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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