II 109th CONGRESS 2d Session S. 3523 IN THE SENATE OF THE UNITED STATES June 15, 2006 Mrs. Feinstein (for herself and Mr. Kyl) introduced the following bill; which was read twice and referred to the Committee on Finance A BILL To amend the Internal Revenue Code of 1986 to provide that the Tax Court may review claims for equitable innocent spouse relief and to suspend the running on the period of limitations while such claims are pending.

1.

Tax court review of requests for equitable innocent spouse relief

(a)

In general

Paragraph (1) of section 6015(e) of the Internal Revenue Code of 1986 (relating to petition for tax court review) is amended by inserting or in the case of an individual who requests equitable relief under subsection (f) after who elects to have subsection (b) or (c) apply. (b)

Conforming amendments

(1)Section 6015(e)(1)(A)(i)(II) of the Internal Revenue Code of 1986 is amended by inserting or request is made after election is filed. (2)Section 6015(e)(1)(B)(i) of such Code is amended— (A)by inserting or requesting equitable relief under subsection (f) after making an election under subsection (b) or (c), and (B)by inserting or request after to which such election. (3)Section 6015(e)(1)(B)(ii) of such Code is amended by inserting or to which the request under subsection (f) relates after to which the election under subsection (b) or (c) relates. (4)Section 6015(e)(4) of such Code is amended by inserting or the request for equitable relief under subsection (f) after the election under subsection (b) or (c). (5)Section 6015(e)(5) of such Code is amended by inserting or who requests equitable relief under subsection (f) after who elects the application of subsection (b) or (c). (6)Section 6015(g)(2) of such Code is amended by inserting or of any request for equitable relief under subsection (f) after any election under subsection (b) or (c). (7)Section 6015(h)(2) of such Code is amended by inserting or a request for equitable relief made under subsection (f) after with respect to an election made under subsection (b) or (c). (c)

Effective date

The amendments made by this section shall apply to requests for equitable relief under section 6015(f) of the Internal Revenue Code of 1986 with respect to liability for taxes which are unpaid after the date of the enactment of this Act.