In the recently issued Notice 2012-8, the IRS proposed a new Revenue Procedure that would revise the threshold requirements for requesting equitable innocent spouse relief. The proposed Revenue Procedure would revise the factors used by the IRS in evaluating requests for innocent spouse relief submitted under Code Sec. 6015(f) when the facts and circumstances warrant. The guidelines would ensure that, when appropriate, requests are granted in the initial stage of the administrative process.

IRS is offering to suspend the issuance of a determination letter denying untimely claims for innocent spouse relief. In most cases, it is in the best interest of the taxpayer claiming relief to request that the IRS suspend the issuance of the determination.