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substantial understatement. The relief granted under section
6013(e) is commonly referred to as innocent spouse relief.
The Enactment of Section 6015
For many taxpayers, relief under section 6013(e) was difficult
to obtain. In order to make innocent spouse relief more
accessible, Congress repealed section 6013(e) and enacted a new
innocent spouse provision (section 6015) in 1998 as part of the
Internal Revenue Service Restructuring and Reform Act of 1998 (RRA
1998), Pub. L. 105-206, sec. 3201(a), 112 Stat. 734. See H. Conf.
Rept. 105-599, at 249 (1998). The newly enacted statute provided
three avenues of relief from joint and several liability: (1)
Section 6015(b)(1) (which is similar to former section 6013(e))
allows a spouse to escape completely joint and several liability;
(2) section 6015(b)(2) and (c) allow a spouse to elect limited
liability through relief from a portion of the understatement or
deficiency; and (3) section 6015(f) confers upon the Secretary
discretion to grant equitable relief in situations where relief is
unavailable under section 6015(b) or (c). Section 6015 generally
applies to any liability for tax arising after July 22, 1998, and
any liability for tax arising on or before July 22, 1998, that
remains unpaid as of such date. See H. Conf. Rept. 105-599, at 251
(1998).
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