Mannella v. Comr., 631 F.3d 115 (3rd Cir. 2011)

(Treas. Reg. Sec. 1.6015-5(b)(1) establishing a two-year statute of limitations for filing of innocent spouse relief claims upheld as valid; I.R.C. Sec. 6015 (b) and (c), but not (f); thus, Treasury can create regulation requiring two year deadline; opinion reverses 132 T.C. No. 10 (2009); case remanded to determine if equitable tolling present). 

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