This article will examine the criticisms of the previous "innocent spouse" provision and proposals for reform that aided Congress in enacting a more equitable provision. The new "innocent spouse" provision, § 6015,' will be dissected to reveal the requirements, as well as the changes from the old provision. Also provided in this article will be examples of the new provision applied to cases decided under the old "innocent spouse" provision. Completing this article will be criticisms of the new provision and I.R.S. actions regarding the new provision.
Note, It's New but Is It Improved: The New Innocent Spouse Provision, 47 Clev. St. L. Rev. 603 (1999)