Notice 2011-70, IR-2011-80

(IRS has issued proposed regulations extending two-year statute of limitations to 10 years for new equitable relief requests from joint liability filed by "innocent spouses; proposed regulations also apply to requests that are currently under consideration; previously denied requests due to two-year limitation may reapply via filing Form 8857 if collection statute of limitations for tax year(s) involved not yet expired; two-year rule not applicable to any pending litigation involving equitable relief, and if litigation final IRS to suspend collection action in certain circumstances; regulations to be issued to formally remove two-year limitation; effective for innocent spouse relief filed on or after Jul. 25, 2011).