Letter 3284C is the IRS's initial contact with the non-requesting spouse after the other spouse asks for innocent-spouse relief. Because granting relief can affect how the joint liability is collected, the IRS must notify both spouses and allow each to provide relevant information.
What the IRS Wants
Read the questions and response date on the letter. The IRS may ask about who earned or reported items, what each spouse knew, who controlled household finances, transfers of property, abuse, or economic hardship. Answer only from facts you know and support important points with records.
This Is Not the Determination
Letter 3284C is an opening notice, not a preliminary ruling granting or denying relief. Later correspondence will explain the IRS's determination and any appeal rights. Do not treat the response date on this initial contact as a Tax Court deadline.
Types of Innocent Spouse Relief
There are three types: traditional innocent spouse relief under Section 6015(b), separation of liability under Section 6015(c) for divorced, separated, or widowed taxpayers, and equitable relief under Section 6015(f) for situations that don't fit the first two categories. The LTR 3284C identifies which type was considered and the outcome for each.
Document Everything
Innocent spouse cases turn on facts: what you knew about your spouse's financial situation, whether you benefited from the understatement, your involvement in the tax preparation process, and whether you suffered economic hardship. Financial records, testimony, and evidence of your spouse's control over finances all matter.
If you've received Letter 3284C, call us at (813) 229-7100. We can help you protect your privacy while providing the facts the IRS should consider.