IRS yesterday issued long-awaited guidance on requests for relief from joint and several liability under Section 6015(f) and Section 66(c). The revised revenue procedure, Rev. Proc. 2013-34, can be found here. Rev. Proc. 2013-34 supersedes Rev. Proc. 2003-61, and was preceded by Notice 2012-8 and Notice 2011-70. The new procedure lists the threshold requirements for requesting equitable relief, conditions on when the Service will make streamlined relief determinations, and also sets out nonexclusive factors it will use to make its equitable relief determinations.
We will describe and analyze the guidance in a future post.