Amid a busy start to the New Year, the BBA U.S. Tax Court Pro Bono Program
celebrated a big win this week. Reaffirming its commitment to providing
assistance to unrepresented litigants and the Court, volunteers from the Program
offer useful and timely legal and tax advice to unrepresented petitioners in Tax
Court.
Earlier this week, the U.S. Tax Court denied an IRS motion for partial
summary judgment and made a critical finding in favor of a taxpayer seeking
innocent spouse relief under section 6015 of the Internal Revenue Code.
Roger Ritt represented the taxpayer with assistance from Amelia Bormann, both of
WilmerHale through the BBA’s Tax Court Pro Bono Program. The court held
that 50% of the funds IRS levied were the taxpayer’s separate property even
though the account was a joint account with her ex-husband. Therefore, the
petitioner is entitled to a refund of a portion of the levied funds if she
establishes her relief under section 6015 at trial. The opinion was issued
as a T.C. opinion, which gives it precedential status.
Congratulations Roger and Amelia!
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| Roger Ritt | Amelia Bormann |