The LTR 3284C is the IRS's preliminary determination on your request for innocent spouse relief under IRC Section 6015. If you filed a joint return with your spouse and the IRS assessed additional tax that you believe is attributable to your spouse's errors or omissions, innocent spouse relief can protect you from liability for your spouse's portion of the debt.
If Relief Was Granted
If the preliminary determination grants relief, the IRS will remove your liability for the portion of tax attributable to your spouse's erroneous items. The IRS must also notify your spouse (or ex-spouse) of the determination, and they have the right to appeal. Your relief isn't final until the non-requesting spouse's appeal period expires or their appeal is resolved.
If Relief Was Denied
If the preliminary determination denies relief, you have 30 days to appeal the decision to the IRS Office of Appeals. You can also petition the Tax Court to review the denial. The Tax Court has jurisdiction over innocent spouse cases under IRC Section 6015(e), and the filing deadline is 90 days from the date of the final determination (which comes after any administrative appeal).
The appeal should address the specific reasons for denial. Common denial reasons include the IRS determined you knew or should have known about the erroneous items, you benefited significantly from the understatement, or the IRS found that equitable relief factors don't weigh in your favor.
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 an LTR 3284C denying relief, call us at (813) 229-7100. The 30-day appeal deadline is critical.