David C. Jonson and Estate of Barbara J. Jonson, Deceased - Page 28

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          were added by the conference agreement reconciling the differing            
          versions of H.R. 2676 passed by the House of Representatives and            
          the Senate, respectively.  See H. Conf. Rept. 105-599, at 251               
          (1998), 1998-3 C.B. 747, 1005.  The reasons for the change with             
          respect to the Senate amendment are described in pertinent part             
          as follows in the report of the Committee on Finance that                   
          accompanied H.R. 2676, S. Rept. 105-174, at 55 (1998), 1998-3               
          C.B. 537, 591:                                                              
                                 Reasons for Change                                   
                    The Committee is concerned that the innocent                      
               spouse provisions of present law are inadequate.  The                  
               Committee believes that a system based on separate                     
               liabilities will provide better protection for innocent                
               spouses than the current system.  The Committee                        
               generally believes that an electing spouse’s liability                 
               should be satisfied by the payment of the tax                          
               attributable to that spouse’s income and that an                       
               election to limit a spouse’s liability to that amount                  
               is appropriate.                                                        
               The conferees did not explain their addition of the                    
          eligibility requirements.  See H. Conf. Rept. 105-559, supra at             
          251, 1998-3 C.B. at 1005.  They did however state that, for                 
          purposes of the eligibility requirements, a taxpayer is no longer           
          married if he or she is widowed.  Id. at 252 n.16, 1998-3 C.B. at           
          1006.  Statements on the floor of the Senate, in support of the             
          Senate amendment, indicate the speakers’ concerns for a wife                
          whose husband had left town or who had otherwise left her with              
          the full joint and several liability imposed by section 6013(d).            
          See statements of Senators Graham and Abraham, reported at 144              

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