Proposed Rule2025-22788
Relief From Joint and Several Liability
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
December 15, 2025
Issuing agencies
Treasury DepartmentInternal Revenue Service
Abstract
This document withdraws two notices of proposed rulemaking regarding relief from joint and several tax liability and relief from Federal income tax liability resulting from the operation of State community property laws. The proposed regulations would have affected married individuals who filed joint returns and later seek relief from joint and several liability.
Full Text
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<title>Federal Register, Volume 90 Issue 238 (Monday, December 15, 2025)</title>
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[Federal Register Volume 90, Number 238 (Monday, December 15, 2025)]
[Proposed Rules]
[Page 57937]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-22788]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-132251-11; REG-134219-08]
RIN 1545-BI82; RIN 1545-BK51
Relief From Joint and Several Liability
AGENCY: Internal Revenue Service (IRS), Treasury
ACTION: Withdrawal of notices of proposed rulemaking.
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SUMMARY: This document withdraws two notices of proposed rulemaking
regarding relief from joint and several tax liability and relief from
Federal income tax liability resulting from the operation of State
community property laws. The proposed regulations would have affected
married individuals who filed joint returns and later seek relief from
joint and several liability.
DATES: As of December 15, 2025, the notices of proposed rulemaking that
were published in the Federal Register on August 13, 2013 (78 FR 49242)
and November 20, 2015 (80 FR 72649), are withdrawn.
FOR FURTHER INFORMATION CONTACT: Mark Shurtliff at (202) 317-6845 (not
a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
On August 13, 2013, the Department of the Treasury (Treasury
Department) and the IRS published a notice of proposed rulemaking (REG-
132251-11) in the Federal Register (78 FR 49242) that proposed guidance
for taxpayers on when and how to request relief from joint and several
liability under section 6015 of the Internal Revenue Code (Code) and
relief from the operation of State community property law under section
66 of the Code (2013 proposed regulations). In addition, on November
20, 2015, the Treasury Department and the IRS published a notice of
proposed rulemaking (REG-134219-08) in the Federal Register (80 FR
72649) that reflected changes to section 6015 made by the Tax Relief
and Health Care Act of 2006, Public Law 109-432, 120 Stat. 2922, 3061
(December 20, 2006), as well as changes in the law arising from
litigation (2015 proposed regulations).
The Treasury Department and the IRS have determined it appropriate
to withdraw the 2013 proposed regulations and the 2015 proposed
regulations at this time to focus time and resources on other matters.
Additionally, in light of the volume and breadth of scope of the
comments received in response to the 2013 proposed regulations and the
2015 proposed regulations, the Treasury Department and the IRS have
determined that further consideration of the proposed rules contained
in the notices of proposed rulemaking is warranted. Moreover, due to
the amount of time that has passed since the notices of proposed
rulemaking were published, the Treasury Department and the IRS do not
intend to publish final rules without again providing additional notice
of the proposed rules and requesting public comments. For these
reasons, the Treasury Department and the IRS are withdrawing the 2013
proposed regulations and the 2015 proposed regulations.
The withdrawal of the 2013 proposed regulations and the 2015
proposed regulations does not limit the ability of the Treasury
Department and the IRS to publish new regulatory proposals regarding
the areas addressed by the withdrawn notices of proposed rulemaking,
including new proposals that may be substantially identical or similar
to those described therein, and the Treasury Department and the IRS may
propose new rules in this regard in a future rulemaking, as
appropriate. In addition, the withdrawal of these notices of proposed
rulemaking does not affect the ongoing application of existing
statutory and regulatory requirements or the responsibility to
faithfully administer the statutory requirements the proposed rules
would have implemented if finalized. Finally, should the Treasury
Department and the IRS decide in the future to move forward with
rulemaking in this area, such rulemaking would take into account
statutory changes that have been made, as well as changes in the law
arising from litigation, since the 2013 proposed regulations and the
2015 proposed regulations were published.
Drafting Information
The principal author of this notice is Mark Shurtliff of the Office
of Associate Chief Counsel (Procedure and Administration). However,
other personnel from the Treasury Department and the IRS participated
in its development.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Withdrawal of Proposed Amendments to the Regulations
Under the authority of 26 U.S.C. 7805, the notice of proposed
rulemaking (REG-132251-11) that was published in the Federal Register
on August 13, 2013 (78 FR 49242), and the notice of proposed rulemaking
(REG-134219-08) that was published in the Federal Register on November
20, 2015 (80 FR 72649), are withdrawn.
Frank J. Bisignano,
Chief Executive Officer.
[FR Doc. 2025-22788 Filed 12-12-25; 8:45 am]
BILLING CODE 4831-GV-P
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</html>Indexed from Federal Register on December 15, 2025.
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.