1. One of your clients is interested in a complicated transaction (a reverse 1031 exchange) that will require the involvement of a “qualified intermediary.” The Code and regulations are unclear about the tax consequences of this specific transaction, but you are aware of the Internal Revenue Service approving similar transactions through letter rulings. As a result, you believe your client should request a P.L.R. before commencing with this transaction.
Please prepare a short correspondence to your client that sets forth the procedural requirements of a private ruling request. You do not need to discuss any specific facts or I.R.C. §1031 in your correspondence.
2. Your client is being audited by the Internal Revenue Service for tax years 2019-2021. Your client was divorced in 2021 and claims to have little knowledge of his spouse’s business dealings, including the preparation of their joint income tax returns.
Prepare a short memorandum that discusses the “Innocent Spouse” defense under I.R.C. §6015(f). You may find Treas. Reg. §1.6015-5(b)(1) and H.R.6089, 111th Cong., 2nd Sess. (2010) helpful in your discussion.
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