The authors review decisions made under Section 6013(e) of the Internal Revenue Code, and conclude that this section has not provided the relief which its enactors intended. They suggest a more liberal reading of this section, so that decisions made will comport with the remedial nature of the statute. The authors also recommend a legislative revision of this section.
James E. Panny and Marc L. Faust,
The Innocent Spouse Provisions of the Internal Revenue Code: In Search of Equity,
32 U. Miami L. Rev.
Available at: http://repository.law.miami.edu/umlr/vol32/iss1/7